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​ 

September 7, 2026
On September 4, 2026, Thailand’s prime minister convened the first meeting of the Data Center Business Policy Committee. The committee endorsed a draft policy framework for the data center industry and tasked four subcommittees with developing the standards that would sit beneath it, shifting away from fragmented, agency-by-agency approvals toward a unified national strategy aiming to maximize economic value while managing environmental and infrastructure concerns. Proposed Scope and Pillars of the National Data Center Policy Framework The proposed framework would cover all types of data centers, including internal or captive facilities operated within a company or its affiliates, rather than only commercial third-party providers. If adopted in this form, companies running private data centers purely for internal purposes would also become subject to regulatory oversight. Minimum safety and operational standards would be established, with uniform enforcement across all categories. The committee endorsed a draft policy framework with four key pillars: Industrial classification: Data centers exceeding 2 MW would be classified as industrial operations, which may require factory licenses and environmental impact assessments under the Factory Act. Resource pricing: Utility rates would be structured to reflect both direct and indirect costs, supporting green energy and green data center standards. Centralized screening: A centralized review would evaluate project suitability and resource allocation. Operators may be required to submit proposals through periodic “pitching” rounds, where projects are competitively assessed on their potential economic and strategic benefits to Thailand. Digital ecosystem: The framework would prioritize data sovereignty, tax incentives, and conditions promoting domestic digital businesses, AI, and cloud infrastructure. Multidimensional Evaluation Criteria and Subcommittees Four subcommittees will be established to develop standards responsible for the following dimensions: Economic: Criteria for assessing the economic viability of data center projects, for use in prioritizing data centers based on infrastructure readiness, demand type (including AI factories),
Read More
September 4, 2026
Foreign business restrictions on telecommunications, treasury center businesses, and intragroup support services were eased when Thailand published the Ministerial Regulation Prescribing Service Businesses Not Requiring Permission for Foreign Business Operations (No. 5) B.E. 2569 (2026) in the Government Gazette on August 28, 2026. The ministerial regulation expands the categories of service businesses that foreign investors may operate without a foreign business license (FBL) under the Foreign Business Act B.E. 2542 (1999) (FBA). Of particular relevance to the telecommunications, fintech, and technology sectors, the ministerial regulation exempts: Type 1 telecommunications licensees, which do not have their own networks; Treasury center businesses operated in accordance with Thailand’s exchange control regulations; and Certain intragroup administrative, human resources, and information technology management services. Telecommunications Services Foreign-owned businesses providing telecommunications services under a type 1 telecommunications license may now operate without obtaining an FBL. This may streamline market entry for qualifying telecommunications and digital infrastructure businesses. The exemption applies only to the FBA licensing requirement. Operators must continue to comply with applicable requirements under the Telecommunications Business Act and the regulations of the National Broadcasting and Telecommunications Commission, and the change does not affect foreign ownership restrictions applicable to type 2 or type 3 telecommunications businesses. Treasury Center Businesses The ministerial regulation also exempts qualifying treasury center businesses from the FBL requirement. This may facilitate centralized treasury functions in Thailand, including liquidity management, foreign exchange management, and intragroup funding arrangements. Treasury center operations remain subject to applicable requirements of the Bank of Thailand and other competent authorities. Intragroup Administrative, HR, and IT Services Certain administrative, human resources, and information technology management services provided between affiliated entities are also exempt, provided the relevant entities satisfy prescribed ownership or management criteria. The exemption is available where the service provider and recipient are related through specified ownership
Read More
September 2, 2026
Thailand and China have a longstanding and significant trade relationship, which increasingly extends to e-commerce and digitally enabled supply chains. While these channels create new opportunities for businesses to reach consumers across borders, their growth also brings greater exposure to intellectual property (IP) infringement across jurisdictions and online platforms. Effective cooperation between the two countries’ enforcement authorities has therefore become increasingly important. To strengthen cooperation in this area, Thailand and China signed a memorandum of understanding (MOU) on IP enforcement in Beijing on July 20, 2026, during the Thai prime minister’s official visit to China. Officially titled “Memorandum of Understanding Between the State Administration for Market Regulation of the People’s Republic of China and the Ministry of Commerce of the Kingdom of Thailand on Cooperation in the Field of Intellectual Property Enforcement,” the MOU forms part of a broader bilateral agenda covering industrial and supply chains, participation by micro, small, and medium-sized enterprises (MSMEs), cooperation associated with the ASEAN–China Free Trade Area 3.0, and progress on the registration of Thai geographical indications in China. The MOU establishes a bilateral framework for cooperation and coordination in five broad areas: Strengthening dialogue in IP enforcement; Enhancing information sharing; Facilitating the enforcement of IP rights in cases arising in the parties’ domestic markets and on online platforms, in accordance with their respective domestic laws; Promoting cooperation in IP enforcement training and human resource development; and Undertaking other cooperation activities agreed upon by both sides. The Department of Intellectual Property (DIP) will serve as the principal coordinating agency for Thailand, while the Bureau of Law Enforcement and Inspection in China’s State Administration for Market Regulation (SAMR) will serve in that role for China. The framework is particularly relevant to the growth of e-commerce, as it covers infringement in the domestic markets and on
Read More
September 2, 2026
On August 21, 2026, Thailand’s Securities and Exchange Commission (SEC) published two consultation papers that would broaden regulated access to crypto assets while tightening custody standards. The first proposes a framework for establishing crypto exchange-traded funds (crypto ETFs) in Thailand. The second proposes enhanced qualification requirements for foreign digital asset custodians serving mutual funds and private funds that invest in digital assets. The proposals seek to expand regulated access to crypto assets while strengthening custody, governance, disclosure, and investor protection, and they affect fund managers, trustees, and licensed digital asset operators. Comments on both papers are due by September 20, 2026, and the SEC expects the resulting rules to take effect later in 2026. Elevating Foreign Custodian Standards Under current rules in effect since January 16, 2025, mutual funds and private funds investing in digital assets may use foreign custodians that meet qualifications similar to those set for domestic digital asset business operators. The SEC now proposes that foreign digital asset custodians satisfy two cumulative requirements: Compliance with the existing baseline qualifications: demonstrated expertise, robust cybersecurity measures, segregation of client assets, controls preventing unauthorized asset transfers, and sound financial standing. Supervision by a regulator that is either (1) an IOSCO Signatory A member under the Multilateral Memorandum of Understanding, the international arrangement through which securities regulators share information and cooperate on enforcement, or (2) a regulator in a jurisdiction that the Thai SEC designates as having adequate supervisory and investor protection standards. The SEC is initially considering 11 jurisdictions for the approved-country list: France, Germany, Hong Kong SAR, Ireland, Japan, Liechtenstein, Luxembourg, Malaysia, Singapore, South Korea, and the United States. The SEC may expand this list over time based on its assessment of other jurisdictions’ regulatory frameworks governing custodian licensing, asset segregation, secure custody practices, client rights in insolvency,
Read More