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

July 11, 2025

Vietnam’s Regulatory Sandboxes: Paving the Way for Digital Innovation

Subscribe to Updates

Vietnam’s recent embrace of “regulatory sandboxes” reflects a deliberate policy choice to balance the need for robust oversight with an equally pressing imperative to catalyze innovation. A sandbox is a controlled, time-bound framework in which businesses may pilot emerging technologies, products, or business models under relaxed or tailor-made regulatory requirements, thereby allowing regulators to observe risks in real time while innovators validate commercial viability without bearing the full weight of the traditional compliance regime.

By issuing sandbox regulations, the government of Vietnam is signaling its commitment to accelerating digital transformation, attracting investment, and developing a knowledge-based economy, all while safeguarding financial stability, consumer protection, and national security. This strategy is embodied in a suite of instruments that together establish sector-specific sandboxes:

  • Decree No. 94/2025/ND-CP on the Regulatory Sandbox in the Banking Sector (Fintech Sandbox Decree), effective July 1, 2025.
  • Law on Digital Technology Industry (DTI Law), effective January 1, 2026, and Law on Science, Technology and Innovation (STI Law), effective October 1, 2025.
  • Resolution No. 222/2025/QH15 on International Financial Centers (IFC Resolution), effective September 1, 2025.

In addition, a draft resolution on the pilot implementation of the crypto-asset market (Draft Crypto Pilot Resolution) is expected to introduce a dedicated sandbox for crypto-asset service providers later this year, further underscoring Vietnam’s holistic, forward-looking approach to regulating emerging technologies.

Below is a brief summary of all the regulatory sandboxes, who they are open for, and what businesses are attracted.

Fintech Sandbox Decree

Under the Fintech Sandbox Decree, besides credit institutions and foreign bank branches, fintech companies operating in Vietnam can apply for a Certificate of Sandbox Participation issued by the State Bank of Vietnam to operate any of the following services in Vietnam:

  • Credit scoring: A solution applicable to information technology systems of credit institutions, branches of foreign banks, and fintech companies to score the creditworthiness of an individual or organization supporting the credit approval by credit institutions and branches of foreign banks.
  • Data sharing via open API: A standardized application programming interface set that may be used by computer systems of credit institutions, branches of foreign banks, fintech companies, and other third parties to send service requests to systems of credit institutions and branches of foreign banks sharing that Open API.
  • Peer-to-peer (P2P) lending: An information technology application solution provided by a P2P lending company to connect borrowers and lenders, and provide assistance for contract conclusion via a digital platform. The currency used in P2P lending solutions must be VND.

The maximum sandbox period is two years, with the possibility of extension of no more than two times, with each extension not exceeding one year.

See our previous article: Vietnam Issues Fintech Sandbox Decree

DTI Law and STI Law

Under the DTI Law, the regulatory sandbox is expressly designed to support and promote the development of “digital technology application products and services”. These products and services are defined to include:

  • Hardware products;
  • Software products;
  • Digital content products; and
  • Services in consultancy, design, installation, integration, management, operation, training, digitization, data processing, warranty, maintenance, repair, refurbishment, publication and distribution of digital technology products; providing digital technology products in the form of services and other digital technology services.

The regulatory sandbox for such products and services will be implemented according to the STI Law.

Under the STI Law, multiple regulatory sandboxes may be established based on government initiatives. In general, these sandboxes require a special license for participation; may provide liability exemptions for participating parties; and are subject to a maximum duration of three years, with a one-time extension of up to an additional three years.

See our previous article: Vietnam’s National Digital Transformation: Key Legal Developments to Expect in 2025

IFC Resolution

Under the IFC Resolution, international financial centers will be organized within specific geographic areas in Ho Chi Minh City and Da Nang, where preferential specific policies for entities registered or recognized as members will be applied.

One such policy is a regulatory sandbox for fintech technologies, products, services, and business models not yet prescribed by law, offering exemption from compliance with standards and technical regulations as well as exemption from liability for damage to the state during experimentation.

The products and services to be provided in the international financial centers include stocks, bonds, fund certificates, financial derivatives, fund management, insurance, reinsurance, banking and foreign exchange, green finance, carbon credits, fintech, digital assets, and other products and services prescribed by the government.

The IFC Resolution does not specify a specific expiry date, but would be replaced by a “Law on International Financial Centers” that is to be proposed in 2034. Approved projects and operation may continue to operate and receive incentives until the end of the project or operation.

See our previous article: Vietnam’s Resolution on International Financial Centers Brings New Opportunities

Draft Crypto Pilot Resolution

Under the Draft Crypto Pilot Resolution, there will be a regulatory sandbox for crypto asset services, including (i) organization of crypto asset transaction/trading markets; (ii) proprietary trading of crypto assets; (iii) custody of crypto assets; and (iv) provision of platforms for crypto asset issuance.

These crypto asset service providers are subject to a joint venture requirement in which the foreign ownership limit is 49%. The entity will need to satisfy stringent requirements to be issued a crypto asset service provider license from the Ministry of Finance.

It is currently contemplated that the regulatory sandbox will run until December 31, 2027. After this, depending on the result of the pilot program, the authority may consider the future legal framework.

Outlook

Vietnam’s regulatory sandboxes represent a significant step forward in fostering innovation and development within the country’s financial and technological sectors. By providing a controlled environment for new and innovative businesses to operate, these sandboxes offer a unique opportunity for companies to test their products and services without the onerous compliance requirements or fears of liability. These initiatives are expected to attract both domestic and international businesses, driving economic growth and positioning Vietnam as a leader in the digital economy.

As these regulatory frameworks take effect, it will be crucial for businesses to stay informed and adapt to the evolving landscape. Now that the Vietnamese government has opened up, the success of these sandboxes will depend on the participation of the business community. The ball is in the private sector’s court.

Related Professionals

Industries

Fintech

Technology

Practices

Banking and Finance

Location

RELATED INSIGHTS​ 

August 10, 2026
On July 31, 2026, Thailand’s Big Data Institute (BDI) launched a public consultation on the principles of a proposed new data-sharing law, with comments accepted until August 31, 2026. If enacted, the law would establish Thailand’s first comprehensive framework for government and private-sector data sharing, creating a systematic, secure, and transparent regime to support analytics, policymaking, research, and innovation. Central Data-Sharing Platform The draft law establishes a central system for data sharing, managed by the BDI. Government agencies would be required to connect to the BDI’s Data Integration and Intelligence Platform (also referred to as D2), in accordance with the BDI’s rules and procedures. Five Dimensions of Data Sharing The draft law covers five key types of data sharing between government (G), businesses (B), and consumers (C): G2B: Private organizations may request government data specifically for research and development purposes. The BDI will assess the applicant’s data governance, security, and privacy capabilities whether such measures meet prescribed standards before forwarding the request to the relevant government agency within 90 days. Any dispute may be escalated to a newly established Data-Sharing Promotion Committee for final determination. G2G: Government agencies may request data from other agencies through the central system. The data-holding agency must respond within 90 days, taking legality, necessity, proportionality, public interest, and personal data protection into account. Disputes may be referred to the Data-Sharing Promotion Committee for adjudication. B2G: In emergency situations involving public safety, economic security, or disaster response, the Minister of Digital Economy and Society may require private entities to provide data through the central data-sharing system. Government agencies must specify the data requested, demonstrate its necessity and expected benefits, and request only data reasonably available to the data holder. Requests for personal data must be limited to the minimum amount necessary. B2C: Royal decrees may
Read More
August 10, 2026
Thailand’s Office of the Personal Data Protection Committee (PDPC) recently released draft guidance on records of processing activities (ROPA) for personal data controllers and processors under the Personal Data Protection Act B.E. 2562 (2019) (PDPA). The draft guidance, which was presented to the public on July 7, 2026, addresses both controller records of collection, use, and disclosure of personal data and processor records of processing activities carried out on behalf of controllers. If implemented, the guidance will significantly expand organizational expectations for ROPA preparation, maintenance, and use across all sectors. Key Takeaways The draft guidance contains several important implications for organizations subject to the PDPA: ROPA reframed as a core accountability tool. The guidance elevates ROPA from an administrative record to a central accountability mechanism, connecting controller duties with recordkeeping obligations. ROPA as a source for privacy notices and governance documents. ROPA should serve as the primary source for privacy notices and align with consent management, retention schedules, DPIAs, incident response plans, and vendor contracts. Expanded scope across all activities. ROPA must cover all processing activities across the organization—including security, finance, HR, and external contractors—with correct controller or processor classification for each. Ongoing maintenance and auditability. ROPA must be updated for any change to systems, purposes, or processors, reviewed at least annually, and maintained with version control and a designated owner. Enhanced vendor, processor, and cross-border transfer requirements. Organizations must document all processors, external recipients, and cross-border transfers, specifying purposes, access scope, and destination countries. Linkage with risk assessment, DPIAs, and LIAs. ROPA should assign risk levels to each activity and identify when data protection impact assessments (DPIAs) or legitimate interests assessments (LIAs) are required, functioning as a risk-management tool. ROPA and data breach readiness. Incomplete ROPA can delay breach response and notification. Organizations should map data flows, vendors,
Read More
August 4, 2026
Thailand’s Personal Data Protection Act B.E. 2562 (2019) (PDPA) could soon see some important changes, as a draft bill to amend the PDPA has been introduced in the House of Representatives. The draft amendment is currently in the public consultation phase, with comments accepted from July 16 to August 15, 2026. If enacted in its current form, the amendment would make three key changes: expanding the government exemption to cover anticorruption operations, introducing a statutory definition of “government agency,” and restructuring the lawful bases for personal data processing to align with international standards. Background The PDPA has encountered several enforcement challenges since its implementation, including three core problems identified by the bill’s sponsors: (1) the current exemptions for government agencies do not cover anticorruption and misconduct-prevention operations; (2) the PDPA lacks a clear statutory definition of “government agency,” causing legal uncertainty as to which entities are covered; and (3) the existing framework for lawful bases of data processing does not align with international standards—particularly the multiple-lawful-bases system in the EU’s General Data Protection Regulation (GDPR)—making compliance inflexible for both government and private sector entities. Expanded Government Exemption The current PDPA exempts government agencies performing duties related to national security (including fiscal security), public safety, anti-money laundering, forensic science, and cybersecurity. The proposed amendment adds “prevention and suppression of corruption and misconduct” to this list of exempted functions. This would allow anticorruption bodies—most notably the National Anti-Corruption Commission (NACC), which is identified as a directly affected party—to collect, use, and disclose personal data without being subject to PDPA requirements when carrying out their duties. New Statutory Definition of “Government Agency” Notably, while the current PDPA use the term “government agency” in several provisions, the term is not comprehensively defined, creating potential uncertainty as to its scope. The draft bill therefore
Read More
August 4, 2026
Tilleke & Gibbins has contributed the Vietnam chapter to Fintech 2027, a global guide published by Lexology Panoramic that provides comparative insights into the legal and regulatory frameworks governing fintech businesses across multiple jurisdictions. The Vietnam chapter offers a comprehensive overview of the country’s rapidly evolving fintech landscape, examining both the regulatory environment and practical considerations for businesses operating in or entering the Vietnamese market. Topics covered include: Fintech landscape and initiatives: General innovation climate; government and regulatory support Financial regulation: Regulatory bodies; regulated activities; consumer lending; secondary market loan trading; collective investment schemes; alternative investment funds; peer-to-peer and marketplace lending; crowdfunding; invoice trading; payment services; open banking; robo-advice; insurance products; credit references Cross-border regulation: Passporting; requirement for a local presence Sales and marketing: Restrictions on the promotion and marketing of financial products and services Cryptoassets and tokens: Distributed ledger technology; cryptoassets; token issuance Artificial intelligence: Regulatory framework governing AI systems and AI-enabled financial services Change of control: Notification and consent requirements for regulated businesses Financial crime: Anti-bribery and anti-money laundering procedures; regulatory guidance Data protection and cybersecurity: Data protection obligations; cybersecurity requirements applicable to fintech businesses Outsourcing and cloud computing: Outsourcing of material functions; use of cloud computing in the financial services industry Intellectual property rights: IP protection for software; employee- and contractor-created IP; joint ownership; trade secrets; branding; remedies for infringement Competition: Competition law issues affecting fintech businesses Tax: Incentives for innovation and investment; developments affecting tax and compliance obligations Immigration: Immigration options for recruiting skilled foreign personnel; special measures available through Vietnam’s international financial centers The chapter also examines a number of significant recent developments shaping Vietnam’s fintech sector, including the introduction of the country’s first comprehensive regulatory framework for cryptoassets, the adoption of a dedicated law on artificial intelligence, implementation of the banking regulatory sandbox,
Read More