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​ 

July 14, 2026
Thailand’s National Broadcasting and Telecommunications Commission (NBTC) has published guidelines establishing a risk-based framework for the responsible use of artificial intelligence by telecom licensees. Released on July 2, 2026, the Guidelines on the Use of Artificial Intelligence for Telecommunications Services address governance structures, ethical principles, lifecycle management, and consumer protection obligations. Scope and Legal Context The nonbinding guidelines apply to holders of telecom business licenses under Thailand’s telecom licensing laws, but only with respect to the use of AI in providing licensed telecom services. Entities without such licenses are not directly subject to the guidelines, though they may be affected as third-party AI solution providers to licensees. The guidelines supplement and should be read alongside existing laws, including the Cybersecurity Act, the Personal Data Protection Act (PDPA), the Computer Crime Act, and the NBTC Notification regarding Measures to Protect Telecommunications Service Users’ Rights Regarding Personal Data, Privacy Rights, and Freedom of Telecommunications, as well as forthcoming AI governance legislation being drafted by the ETDA. AI Governance Structure Licensees are expected to establish committees, working groups, or designated officers at both policy and operational levels to set strategic direction for AI use, formulate governance policies and tools, and oversee risk management. Roles, responsibilities, and accountability should be clearly defined for all personnel across every stage of the AI lifecycle—including for third-party AI solution providers and outsourced service providers, whose obligations should be explicitly documented in service agreements. Core Principles The guidelines identify six core principles that licensees should adhere to when deploying AI: Compliance with laws, ethics, and international standards: AI should respect privacy, dignity, and human rights, and content filtering for inputs and outputs should be considered. For example, the AI should not be designed and developed to be used in generating false information, supporting illegal activities, or causing
Read More
July 10, 2026
Vietnam has taken a significant step in regulating its e-commerce sector with the issuance of a new decree guiding the country’s recently enacted Law on E-Commerce. Decree No. 248/2026/ND-CP, issued on June 30, 2026, and taking effect the following day, addresses mandatory platform policies, registration requirements for offshore platforms, additional obligations on platform operators, and market access conditions for foreign investors. Mandatory Policy Contents The decree sets out detailed guidance on the required contents of various platform policies, covering pricing, payment, display priority, livestream sales, delivery, returns, method of service provision, and service termination and refunds. Clarification of Obligations for Platform Operators The decree provides clarification of the obligations applicable to platform operators. Notably, intermediary e-commerce platform operators with online ordering functions must: Collect specific information to implement electronic identity verification of sellers; Cooperate with regulators by reporting online through the state e-commerce management system and by blocking, suspending, or removing content upon request of a competent authority; Maintain a mechanism to store contract data, including price, product or service information, and parties’ information, for at least three years from the date of contract conclusion; and If qualifying as a “large digital platform” under consumer protection law, maintain an online system for receiving and handling complaints and requests, and comply with enhanced content-removal requirements. Registration Requirements for Offshore Platforms Offshore e-commerce platforms, whether direct-sales, intermediary, social-network-based, or integrated, that conduct e-commerce activity in Vietnam must register with the Ministry of Industry and Trade if the platform: Allows Vietnamese-language selection; Uses a “.vn” domain; or Reaches 100,000 or more transactions with Vietnam-based buyers within a calendar year. Notably, the registration requirement now captures not only traditional intermediary platforms, but also direct-sales platforms. Foreign Investment Conditions Foreign investors holding a controlling interest in an intermediary e-commerce platform, a social media platform
Read More
July 8, 2026
On July 7, 2026, the Trade Competition Commission of Thailand (TCCT) issued a press release announcing the establishment of two new subcommittees designed to intensify oversight of digital platforms and modern trade businesses. The formation of the digital platform subcommittee marks a significant escalation in competition enforcement following the TCCT’s Guidelines on Multi-Sided Platforms and E-Commerce Businesses, which took effect on March 25, 2026. Platform operators, sellers, and related service providers should expect heightened regulatory scrutiny and potential investigations into practices already flagged under the March guidelines. Two Dedicated Enforcement Bodies The first new body is the digital platform subcommittee—formally the Subcommittee on Supervision, Monitoring, and Prevention of Trade Conduct in Digital Platform Business. It is tasked with driving intensive oversight of digital platform businesses. It will coordinate with government agencies, the private sector, business operators, and other relevant stakeholders to supervise and prevent trade conduct that may affect competition, and to promote free and fair competition in the digital platform sector. The subcommittee will be composed of TCCT members and representatives from the Department of Internal Trade. The second body—the Subcommittee on Determining Guidelines and Action Plans Concerning Competition Conditions in Modern Wholesale and Retail Business—will study, analyze, and monitor market structure in modern wholesale and retail businesses, compile databases to analyze retail business concentration, assess impacts on small-scale operators, and propose supervisory measures for the retail sector. TCCT members will serve on the subcommittee alongside experts from government and private organizations, including the Office of Industrial Economics, the Office of Small and Medium Enterprises Promotion, the Thai SME Federation, and the Thai SME Council. Operational Impact for Industry Participants These subcommittees provide the TCCT with a focused mechanism to investigate various trade practices deemed unfair, and the TCCT has authority under the Trade Competition Act to issue cease-and-desist
Read More
July 6, 2026
Vietnam has introduced an official list of high-risk AI systems, triggering more stringent compliance obligations for developers, suppliers, and deployers operating in the country. On June 30, 2026, the prime minister issued Decision No. 33/2026/QD-TTg (Decision 33), which establishes the List of High-Risk AI Systems under the Law on Artificial Intelligence (AI Law) and Decree No. 142/2026/ND-CP (Decree 142). Decision 33 takes effect on August 15, 2026. Decision 33 is significant because only AI systems included on the list will be subject to the heightened compliance obligations applicable to high-risk AI systems under the AI Law and Decree 142. These include, among others, local presence requirements for foreign providers, mandatory conformity assessment before deployment, comprehensive risk management and data quality documentation, and strict liability for damages even when the provider is fully compliant. Decision 33 also specifies the applicable conformity assessment pathway for each listed system, indicating whether the system must undergo mandatory third-party conformity certification before being placed into use, or whether the provider may self-assess conformity or voluntarily engage a registered or recognized conformity assessment body. Which AI Systems Are Covered? Decision 33 identifies high-risk AI systems across six sectors—the key attributes of which are summarized below. Education: AI systems used for automated assessment, learner ranking, behavioral monitoring, or generating educational content from uncontrolled data sources. Ethnic affairs and religion: AI systems used to automatically score, classify, or rank applications for government ethnic policies; approve or reject regulatory applications; suspend benefits on suspicion of fraud; allocate budgets; or infer and classify individuals by ethnicity or religion for administrative purposes. Healthcare: AI-assisted surgical systems and autonomous AI-powered surgical robots. Banking: AI systems that autonomously conduct electronic banking transactions or make credit approval decisions. Judicial proceedings: Certain large-scale biometric identification systems used in public-interest civil proceedings. Transport: Thirty-one categories
Read More