You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

March 15, 2024

Vietnam Revs Up Fintech Sector with Updated Draft of Sandbox Decree

Subscribe to Updates

Vietnam’s fintech industry is booming, and the rapid emergence of tech startups and non-bank institutions offering innovative financial services has been outpacing existing regulations. This regulatory gap not only creates uncertainty for both innovators and consumers, but also poses a number of imminent risks in areas such as consumer protection, data privacy, cybersecurity, and anti-money laundering, among others.

The State Bank of Vietnam (SBV) is stepping up to tackle these challenges by accelerating the promulgation of a long-awaited Fintech Sandbox Decree with the issuance of an updated draft (“Draft Fintech Sandbox Decree”) on March 4, 2024. The Draft Fintech Sandbox Decree establishes a controlled environment where fintech companies and financial institutions can test solutions that do not fall squarely within the parameters of existing regulations. The pilot activities will be limited in scope, scale, and duration, with a number of precautionary measures in place. The SBV will supervise this “sandbox” closely, effectively mitigating risks and gathering valuable data to inform future regulations.

Who Can Participate in the Sandbox?

  • Traditional financial institutions (credit institutions): Banks and other institutions licensed to provide financial services can participate in the sandbox to test new offerings or refine existing ones.
  • Independent fintech companies: Startups and established companies specializing in fintech solutions can leverage the sandbox to pilot innovative ideas before seeking wider market adoption.
  • Other relevant organizations involved in the pilot: Depending on the specific solution being tested, other entities may also be involved in the sandbox.
  • Geographical scope: Limited to Vietnamese territory; cross-border testing is not allowed.

Focusing on Three Solution Categories

Earlier versions of the Draft Fintech Sandbox Decree included categories like blockchain technology and other innovative business models, but these were removed in the latest version. To allow the SBV to assess the associated risks and work on the solutions more effectively, this version focuses only on the following three solutions:

  • Credit scoring: Fintech companies can pilot new credit scoring models to assess the creditworthiness of individuals or organizations.
  • Data sharing via Open Application Programming Interface (“Open API”): Secured data-sharing mechanisms using Open APIs can be tested within the sandbox.
  • Peer-to-peer lending (“P2P Lending”): Platforms that connect lenders and borrowers can be piloted in the sandbox.

Participation Conditions

Fintech companies must meet specific criteria depending on the solution they are piloting. The criteria will vary depending on the complexity and potential risks associated with the solution. For example, P2P lending platforms might face strict requirements on cybersecurity and network information security.

All participants must submit a registration dossier and obtain a Certificate of Participation from the SBV.

Monitoring and Risk Control

The SBV will closely monitor activities, evaluate participation, and assess the effectiveness of the piloted solutions, with a dedicated team to oversee activities within the sandbox, ensuring that participants comply with applicable regulations and that pilots are conducted safely and effectively.

Participating organizations are required to submit regular reports and provide ad hoc information on the pilot process, operational indicators, risks encountered, and the results of the pilot implementation to the SBV.

Customer Protection

Participating organizations have a responsibility to ensure customer rights and interests. This includes informing them about potential risks associated with using the piloted solution, obtaining their informed consent, and clearly outlining data privacy practices.

Participating organizations must implement robust security measures to safeguard customer data collected during the pilot program.

For dispute settlement, organizations are required to establish a customer complaint handling department and have clear mechanisms in place to address any disputes or complaints arising from the use of their piloted solutions.

Sandbox Conclusion

The pilot period will last a maximum of two years, with the SBV having the authority to adjust the length based on the actual implementation. After the pilot period, the SBV will decide on the next steps based on participating organizations’ reports, its own monitoring data, and any feedback received from relevant state authorities. Options will include terminating the pilot, certifying its completion, or extending the pilot period.

Participation in the Sandbox Mechanism does not guarantee an operating license or market approval for the piloted solutions.

Outlook

Once it is officially passed, it is hoped that the Fintech Sandbox Decree will usher in a new era of controlled experimentation in the sector, fostering a dynamic fintech ecosystem where innovation can thrive alongside robust regulations. By balancing innovation with consumer protection, cybersecurity, and data protection, it has the potential to transform Vietnam into a hub for groundbreaking fintech solutions, all while safeguarding the integrity of the financial system and consumers’ interests.

Now that the sandbox program has been streamlined to include only the three most prominent fintech solutions, the SBV might be able to speed up the official issuance of the Fintech Sandbox Decree.

Related Professionals

Industries

Technology

Practices

Banking and Finance

Location

RELATED INSIGHTS​ 

June 23, 2026
On May 26, 2026, Thailand’s Department of Land Transport (DLT) published for public consultation a draft amendment to the Ministerial Regulation on Electronic Ride-Hailing Vehicles that would, for the first time, allow juristic persons (legal entities) to register vehicles as electronic ride-hailing cars—a right that currently belongs exclusively to natural persons, limited to one person per one vehicle. If finalized in its current form, the regulation would significantly expand the supply side of Thailand’s ride-hailing market by enabling corporate fleet operators to enter the space. The public comment period is open through June 24, 2026. Key Principles Under the Draft Regulation Under the proposed amendment, juristic persons that maintain a fleet of at least 50 vehicles will be permitted to register vehicles as electronic ride-hailing cars. This represents a fundamental shift from the current framework, which restricts registration to individual natural persons on a one-person-one-car basis. Vehicle Specifications Corporate-owned ride-hailing vehicles must meet the following requirements: Be brand new from the factory, or no more than two years old from first registration with no more than 20,000 km of use. Not be a vehicle that has been reconstructed or repaired after involvement in a serious accident affecting safety—a standard consistent with public transport vehicles (RorYor. 6). Be classified as small, medium, or large in accordance with ministerial or director-general specifications. The vehicles may be equipped with safety devices such as interior or exterior cameras (video/photo recording) and can retain the original factory color of the vehicle body (no mandatory color change is required). License Plates Corporate ride-hailing vehicles will use license plates of the same size, characteristics, and color as those for private passenger vehicles not exceeding seven seats (RorYor. 1), rather than public transport plates. Potential Impact The government has stated that the regulation is intended to: Promote
Read More
June 23, 2026
On May 14, 2026, Thailand published a ministerial regulation in the Government Gazette to prescribe measures for prevention and suppression of technology crimes. The regulation creates a comprehensive procedural framework for returning money and digital assets to victims of technology crimes. It will take effect 90 days after publication (in mid-August 2026), giving affected entities a limited window to prepare. Mandatory Reporting Obligations for Financial Institutions When a deposit account, e-money account, or digital asset wallet is frozen in connection with a technology crime, the relevant financial institution or business operator must report transaction data to the Anti-Money Laundering Office (AMLO) via AMLO’s designated electronic system. Required data elements include account numbers (sender and receiver), names, identification or passport numbers, legal entity registration numbers, phone numbers, remaining balance, damage amount, transaction reference numbers, and the bank case ID. Institutions that already share data through the information-sharing system under the emergency decree are deemed to have satisfied this reporting obligation, creating an incentive for platform participation. When the Royal Thai Police or the Department of Special Investigation seize or freeze assets related to technology crimes, they must provide AMLO with investigation reports, complaint evidence, money-trail data, and account statements. Notification and Claims Process Once the AMLO secretary-general approves verified reports of a technology crime, the account information of persons connected to the crime will be published in the Government Gazette, triggering a 90-day window for victims to file claims and for related persons to file objections. Officers will also publish details on AMLO’s electronic media and send registered mail to identified victims, which will be deemed received after 7 days domestically or 15 days internationally. Victims have 90 days from the date the crime is published in the Government Gazette to file claims through AMLO’s electronic system. Claims must include
Read More
June 15, 2026
The surge in AI development has led to a desperate demand for large, high-quality training data. However, real-world data can be expensive to collect, difficult to access, and often subject to strict privacy and regulatory constraints. Synthetic data, which consists of artificially generated records that replicate the statistical properties of real-world data without reproducing specific individuals’ information, provides an appealing solution by generating artificial datasets at scale without relying on identifiable personal information. It combines speed, cost efficiency, and regulatory compliance, making it a sensible alternative for organizations seeking to reduce risks while maintaining data utility. When properly anonymized, synthetic datasets may fall outside the scope of laws such as the EU’s General Data Protection Regulation (GDPR) or Thailand’s Personal Data Protection Act (PDPA), reducing compliance burdens while still supporting high-quality model training. However, relying on synthetic data without rigorous legal due diligence could be a strategic mistake. It replaces one set of known risks (scraping, direct privacy liability) with a new set of complex liabilities. The narrative that synthetic data is a “silver bullet” for privacy and IP compliance is dangerous and could be misleading. While synthetic data addresses data scarcity, it also introduces new legal uncertainties. Legal counsel should anticipate downstream risks arising from compromised data sources. Models trained on unlawfully obtained data may need to be decommissioned, even if their outputs appear lawful. What is synthetic data? Synthetic data refers to artificially generated information created using AI techniques such as deep learning and generative models. Instead of copying real records, it reproduces the statistical patterns and relationships found in the original dataset. Synthetic data generally falls into three categories: Fully synthetic data – Entirely new data points generated from learned patterns. The model studies the structure of the original data and produces records that resemble real-world
Read More
June 11, 2026
Thailand’s Electronic Transactions Development Agency (ETDA) has released a revised draft Electronic Transactions Act (ETA) for public hearing from May 12, 2026, to June 15, 2026. This is not merely an amendment to certain provisions of the current ETA, but a comprehensive redrafting of the entire act. The revised draft ETA introduces several significant changes from the current framework, with practical implications for businesses operating in Thailand. Unified Coverage of Public and Private Sectors The current law segregates government transactions into a separate chapter with distinct rules. The draft ETA eliminates this division, defining “transaction” to encompass civil and commercial juristic acts as well as administrative procedures, administrative contracts, and other acts of government agencies. Enhanced E-Signature Definition The definition of “electronic signature” is broadened to expressly include biometric data and refocused on identifying the signatory and demonstrating intent regarding the content of the electronic data. Shift in Burden of Proof When a party challenges the reliability of electronic data created using a “trusted electronic method” or a method prescribed by the ETDA, the burden of proof and the cost of proving unreliability shifts to the challenger. Introduction of New Digital Method Concepts The draft ETA introduces several new digital method concepts that are not currently recognized under the existing ETA framework. These include: Electronic timestamping (e-timestamp) Electronic registered delivery Electronic company seals Electronic stamp duty compliance Electronic identity authentication and verification Electronic transferable records (electronic bills of lading, promissory notes, and similar negotiable instruments) Recognition of Automated Systems and Electronic Contracting The draft ETA expressly recognizes the legal validity and enforceability of contracts formed through automated systems, including contracts concluded entirely between automated systems or between an automated system and a person. A party may not deny the binding effect of such contracts solely because no human review
Read More