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​ 

December 26, 2025
The Bank of Thailand (BOT) has released the Guidelines for Digital Fraud Management, which took effect on December 17, 2025, incorporating certain amendments to the draft guidelines issued in March 2025. These official guidelines aim for end-to-end digital fraud prevention, with a particular focus on mule accounts, to enhance trust and security in Thailand’s financial system. The guidelines apply to “financial service providers,” including: Financial institutions and special financial institutions under the Financial Institution Business Act; and Operators of Inter-institutional Fund Transfer System e-money services and e-fund transfer services under the Payment Systems Act. Besides commercial banks and e-money operators that offer fund-transfer services, other providers may adopt requirements based on risk proportionality and baseline standards set out in the guidelines (for instance, an e-money operator that does not offer e-fund transfer services could consider implementing a fraud monitoring and detection system according to the risk level of its service). The guidelines establish the following key requirements: Policy and oversight. Directors and senior executives of financial service providers must adopt appropriate “end-to-end” fraud management policies and KPIs to manage digital fraud, covering prevention, monitoring, detection, management, resolution, and support for affected customers. The fraud management policy must be regularly reviewed, and whenever there is a situation or change that significantly affects the efficiency of the fraud management. Any significant update to the policy must first be approved by the board of the financial service provider. The BOT also encourages providers to collaborate in establishing industry standards aligned with applicable laws and regulations to ensure consistency and best practices across the sector. Fraud management processes. Financial service providers must establish a clear framework for managing digital fraud throughout the customer lifecycle—from customer onboarding to service termination—covering at least the following processes: Know your customer (KYC) and customer due diligence (CDD):
Read More
December 15, 2025
Thailand is taking steps to energize its startup scene by drafting the Startup Promotion Law. This draft law aims to remove obstacles, open new funding opportunities, and provide coordinated government support. The goal is to make it easier for Thailand-based startups to grow and compete on a global stage. Why Is This Law Needed? For many years, Thai startups have operated under traditional company law frameworks that were not designed with high-growth businesses or with fundraising opportunities in mind. Restrictions on issuing bonds, offering shares to outside investors, and repurchasing shares for employee incentive programs made it challenging for emerging companies to access capital and accelerate their growth. The draft Startup Promotion Act seeks to remove these obstacles and foster a more competitive, entrepreneur-friendly environment in Thailand. Who’s in Charge? Two main organizations will oversee the startup ecosystem: Startup Promotion Committee: This group, to be appointed by the National Science, Research, and Innovation Policy Council, will set national strategies, policies, and budget; design promotional campaign and incentives; and propose further legislative amendments to promote startups. National Innovation Agency (NIA): Under the draft act, the NIA will be the main contact for startups and will serve as the secretariat office of the Startup Promotion Committee, coordinating data, advising startups, maintaining the public registry, and providing funding and investment (grants, repayable grants, loans, and equity) under committee criteria and, where applicable, cabinet approval. What Startups Are Eligible for Benefits? To be officially recognized and access benefits, a company must: Be a private limited company less than 10 years old at the time of application. Existing companies that already exceed the 10-year threshold may still apply for startup statues within one year of the law’s enactment, as long as they otherwise still qualify for the new regime. Have average annual revenue not
Read More
December 12, 2025
Tilleke & Gibbins has updated the Cambodia, Myanmar, Thailand, and Vietnam chapters in Multilaw’s Global Data Protection Guide, which collects expert advice from Multilaw member firms in 90 jurisdictions around the world (including a Laos chapter, which is also authored by Tilleke & Gibbins). The guide provides answers to key issues concerning the fast-developing data protection and privacy laws around the world, and helps data protection officers and in-house counsel understand how the regulatory regime for data protection can affect their organizations in various jurisdictions. Each section of the guide identifies the main laws that govern data protection in that jurisdiction, and gives a detailed overview of the legal principles in place as well as the enforcement authorities responsible for overseeing compliance. The guide also covers issues related to data subject rights, data protection officers, impact assessments, data breach notification requirements, and cross border data transfers. The use of personal data in marketing is also considered, with specific information on electronic marketing rules, cookies, and marketing to businesses and consumers. Multilaw, of which Tilleke & Gibbins is a longtime member, is a global network of carefully selected independent law firms able to provide expert legal advice in complex environments around the globe. The full guide is available for free on the Multilaw website.
Read More
December 11, 2025
On December 10, 2025, the National Assembly of Vietnam passed a new Cybersecurity Law, which will take effect on July 1, 2026. The new Cybersecurity Law was developed based on the consolidation of the 2018 Cybersecurity Law and the 2015 Law on Network Information Security. While the final approved version of the new Cybersecurity Law has not yet been published, according to official reports, the following notable requirements are confirmed to be included: The new Cybersecurity Law dedicates a specific article to prohibited acts related to cybersecurity, under which it strictly prohibits posting or disseminating information online that propagandizes against the Socialist Republic of Vietnam. The law also prohibits, among other things, (i) the appropriation, trading, seizure, or intentional disclosure of information classified as state secrets, work secrets, business secrets, personal secrets, family secrets, and private life; (ii) intentionally eavesdropping, recording, or filming online conversations without authorization; and (iii) the use of artificial intelligence (AI) or new technologies to conduct prohibited acts. The Ministry of Public Security (MPS) has the authority to require enterprises providing telecommunications, internet, and online services, as well as system administrators, to remove information violating cybersecurity laws from systems under their management. The MPS is also assigned responsibility for ensuring information security in cyberspace and data security, establishing mechanisms for IP address identity management, verifying digital account registration information, and issuing warnings and sharing information on cybersecurity threats. Information systems are classified into five levels (similar to the 2015 Law on Network Information Security) based on the degree of harm to national security and social order if an incident occurs. The MPS is the lead agency assisting the government in state management of cybersecurity. The Ministry of National Defense is responsible for managing military information systems, and the Government Cipher Committee manages cryptographic and cipher
Read More