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​ 

November 7, 2025
Tilleke & Gibbins has contributed the Thailand chapter to the latest edition of the Global FinTech Guide published by Multilaw. The guide offers an overview of the legal and regulatory environment for financial technology across key jurisdictions worldwide. Prepared by leading experts from Multilaw member firms, the Global FinTech Guide explores how innovation is reshaping the financial sector and how governments and regulators are responding to emerging technologies such as digital payment services, cryptocurrencies, and online financial advisory platforms. The publication enables quick comparison of regulatory frameworks and provides detailed country-level insights for investors, startups, and established financial institutions engaging in FinTech activities. The Thailand chapter, authored by lawyers in Tilleke & Gibbins’ technology and financial services teams, outlines the country’s evolving regulatory landscape for fintech operations. It addresses the following topics: Payment services Asset and portfolio management Financial advisory and broking services (including robo-advisory and auto-trading) Trading platforms, social trading platforms, and signal following Crowdfunding, crowdinvesting, and crowdlending DLT and cryptocurrencies Loan services, factoring, loan broking, and finetrading Identification Online banking services Initial coin offerings (ICOs) and token sales Insurtech Regtech and compliance management Know-your-customer (KYC) requirements Tilleke & Gibbins also contributed the Vietnam chapter to the Global FinTech Guide. The full guide is available on the Multilaw website.
Read More
October 31, 2025
On September 29, 2025, Thailand’s Office of the Personal Data Protection Committee (PDPC Office) published its Regulations on the Review and Certification of Binding Corporate Rules B.E. 2568 (2025) (the Regulations). The Regulations provide clarity on the PDPC Office’s approach to reviewing and certifying binding corporate rules (BCRs) under Section 29 of the Personal Data Protection Act B.E. 2562 (2019) (PDPA), and aim to facilitate international data transfers within a group of undertakings or enterprises (a “corporate group”). In conjunction with this development, the PDPC Office also approved BCRs for two companies operating in Thailand on September 30, 2025. This milestone represents the first concrete progress since the PDPC’s Notification on Criteria for the Protection of Personal Data Sent or Transferred to a Foreign Country pursuant to Section 29 of the PDPA B.E. 2566 (2023) came into effect in March 2024. Some key features of the Regulations are set out below. Categorization of BCRs BCRs are classified into two types: (1) BCRs for Controllers (BCR-C) and (2) BCRs for Processors (BCR-P). The category must be clearly specified when submitting the BCRs to the PDPC Office. Documentation Requirement The applicant must prepare and submit the application (a standard template may be provided by the PDPC Office in the future) along with supporting documents for review and certification in the Thai language. If the supporting documents are in a foreign language, a certified Thai translation should be provided. The translation must be notarized by a notary public or qualified person. Supporting documents may include, among others, a binding instrument such as an intra-group agreement, or a list of entities subject to the BCRs. Expedited Process Requirement Organizations with existing BCR approvals under the EU or UK GDPR, or from countries announced by the PDPC under Section 28, may apply through an
Read More
October 26, 2025
AI-generated songs are now making waves in Vietnam on platforms like TikTok, with tracks such as “Say mot doi vi em” quickly gaining popularity and sparking widespread attention. This phenomenon raises a host of legal and ethical questions: Who is the author of these songs? Can they be protected by copyright? Who is responsible if there is an infringement? These questions are becoming increasingly urgent as AI music becomes more mainstream in Vietnam. Copyright Protection for AI-Generated Music in Vietnam Under current Vietnamese law, copyright protection is reserved for works that bear the mark of human creativity. The 2022 amendments to Vietnam’s Intellectual Property Law reaffirm that only works created by humans are eligible for copyright. In practice, if a human meaningfully contributes to the creative process—by providing prompts, making selections, editing, or arranging—their contribution may be protected. However, if a song is generated entirely by AI without significant human input, it is unlikely to qualify for copyright protection. When an AI-generated song does not qualify for copyright protection, the question arises as to whether the person who writes the prompts, edits, or compiles the work can still be considered the owner of an asset under the Vietnamese Civil Code. According to Article 105 of the Civil Code 2015, assets include objects, money, valuable papers, and property rights. While AI-generated music that is not protected by copyright is not considered money or valuable papers, it may be regarded as an object (in the form of a digital file or recording) or as a property right if it can be possessed, used, transferred, or exploited for value. Use of AI-Generated Works Without Copyright Protection If a song is not protected by copyright, does that mean anyone can use it freely? Not necessarily. The absence of copyright does not mean the
Read More
October 3, 2025
On September 26, 2025, the Contract Committee under Thailand’s Consumer Protection Board issued a regulation that aims to standardize contracts and enhance consumer protection within the beauty and wellness industry. The Notification on Prescribing the Beauty Service Business as a Contract-Controlled Business B.E. 2568 (2025), which takes effect on January 24, 2026, requires business operators to use a prescribed standard contract in Thai and adhere to strict mandatory provisions and prohibitions. These regulations apply to operators across all in-person and online service channels, including via digital platforms. “Beauty services business” is defined as the provision of services under an agreement allowing consumers to receive a series of treatments, either over a set number of sessions or within a set period. This includes massage, spa, other methods for cleanliness, beauty, or care of facial or body skin, and weight control and body shaping—including services offered electronically. The law excludes surgery, liposuction, and medical treatments performed by licensed practitioners. The notification establishes the following key requirements: Mandatory contract and formatting. All contracts with consumers must use the standard contract form, in Thai, with clear, readable text (minimum font size of 2 millimeters, no more than 11 characters per inch), and include all essential terms from the annexed form. Contract execution. Contracts must be made in duplicate, with one copy given to the consumer at signing. For agreements concluded through electronic channels, the process must comply with the Electronic Transactions Act and use the same required terms. Digital platforms. Business operators who provide services facilitated through a digital platform as an intermediary are ultimately responsible for ensuring the consumer receives a compliant contract. Prohibited clauses. The law prohibits clauses that limit or exclude liability for damages to life, body, health, mind, or property resulting from breach of contract or a wrongful act;
Read More