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​ 

February 26, 2026
Thailand is preparing to offer new tools for intellectual property enforcement as the Electronic Transactions Development Agency (ETDA) recently released for public consultation a draft notification requiring social media platforms to verify user identities and conduct know-your-customer (KYC) checks on advertisers. The draft Notification of the Electronic Transactions Commission on Measures to Prevent Technological Crimes for Social Media Service Providers, which is to be issued under the Emergency Decree on Measures for the Prevention and Suppression of Technological Crimes B.E. 2566 (2023), as amended in 2025, primarily aims to combat online fraud and technology-related crimes. However, its new obligations also provide IP owners with valuable tools to identify anonymous infringers. Key Regulatory Mandates The draft notification imposes several verification requirements on social media platforms operating in Thailand. These requirements also strengthen IP rights holders’ ability to identify anonymous infringers, as platforms must: Verify user identities through registered phone numbers and link all accounts to verifiable identities. Conduct KYC checks on advertisers, including individuals, companies, and any third-party payers. Perform heightened identity checks for high-risk or repeat offenders before publishing advertisements. Promptly remove content flagged by the Anti-Technology Crime Division and prescreen advertisements for prohibited or high-risk content. How IP Owners Can Use This Notification for Enforcement The phone number–based verification requirement enables IP owners to work more effectively with enforcement authorities in tracing individuals or entities responsible for infringing content. The comprehensive advertiser KYC obligations, including mandatory disclosure of third-party payment sources, create a clear audit trail even when bad actors attempt to obscure their identity through intermediaries or shell accounts. This traceability is essential for pursuing damages and dismantling organized counterfeit operations. The ETDA is now considering adjustments to the draft notification after receiving comments during the public consultation period, which ended on February 2, 2026. Following finalization
Read More
February 23, 2026
On February 17, 2026, Thailand’s Personal Data Protection Committee (PDPC) released its draft Guidelines on Personal Data Protection in the Development and Use of Artificial Intelligence. The draft guidelines, which translate data controller and data processor compliance obligations under the Personal Data Protection Act (PDPA) into measures tailored to AI development and deployment, are open for public comment until February 25, 2026. At a public hearing session on the draft guidelines held on February 19, the PDPC emphasized that its approach to AI is not to hinder innovation but to develop practical guidance supporting safe deployment while ensuring data protection. Although the guidelines are not legally binding, they indicate the regulator’s expectations and the likely direction of interpretation and enforcement. Scope of Application and Role of Stakeholders The guidelines will apply to all data controllers and data processors in Thailand, and to overseas data controllers and data processors whose data processing falls within the extraterritorial scope of the PDPA. The draft guidelines distinguish the roles of parties involved in AI deployment. Users of AI who determine the purpose of use and designate the input data, and retain outputs generated by the AI, are considered data controllers. In contrast, AI model providers or system integrators that process personal data under the instructions of the data controller are generally regarded as data processors. However, if an AI model provider utilizes user data for its own purposes, such as model fine-tuning or training, it may instead be classified as a data controller. Key Obligations for AI Data Collection and Use The basic principles of data processing under the PDPA must be maintained throughout the AI implementation lifecycle, from design to decommissioning, emphasizing accountability and privacy-by-design principles. The draft guidelines also stipulate the following: Data processing agreements (DPAs) should include model training prohibitions,
Read More
February 10, 2026
Data center and cloud investments are forming a major focus of private-sector investment in Thailand, with tech giants like Amazon, Google, Microsoft, and TikTok, as well as numerous telecom and data center companies, committing significant outlays to data center and cloud development. The country’s Board of Investment (BOI) approved projects worth THB 1.87 trillion in 2025, and THB 746 billion of this was from planned data center investments—by far the largest amount from any single industry. Thailand’s swift rise as a regional data center hub is fueled by surging demand for cloud, AI, and digital services, as well as large-scale investments from global tech firms. The country’s strategic location, competitive power costs, robust fiber infrastructure, expanding IT talent, and supportive government policies—including BOI incentives and streamlined approvals—have made it an attractive destination for scalable and sustainable digital infrastructure investments. The BOI’s proactive approach in updating promoted categories and providing both tax and non-tax incentives further ensures Thailand’s continued growth in this sector. 2025 BOI Changes for Data Centers In the middle of 2025, the BOI responded to the remarkable trend by updating investment‑promotion categories across various sectors (e.g., machinery and electrical equipment, public utilities, digital and innovative industries) to accommodate growing investment in data‑center projects. Before the change, which was detailed in a notification that has applied to investment promotion applications submitted from July 1, 2025, onward, data‑center projects under BOI promotion were granted a single A1 incentive (an eight‑year corporate income‑tax exemption) and subject to one uniform set of conditions. The July 2025 notification restructured promotion for data centers into two categories based on power‑usage efficiency: high‑efficiency data centers and other data centers. Under these rules, qualified high‑efficiency data centers are eligible for an eight‑year corporate income tax (CIT) exemption, while for other data centers this exemption is
Read More
February 4, 2026
On November 18, 2025, Vietnam’s Ministry of Finance released for public consultation a draft decree on administrative sanctions in the field of crypto assets and crypto asset markets (the “Draft Decree”), intended to implement Resolution No. 05/2025/NQ-CP dated September 9, 2025, on the pilot crypto asset market in Vietnam (“Resolution 05”). While Resolution 05 sets out who may participate and under what conditions, the Draft Decree addresses a more practical question for market participants, i.e., what happens if those conditions are not met. In doing so, the Draft Decree offers important insight into how Vietnamese regulators intend to supervise, discipline, and ultimately shape the crypto market during the pilot phase. Regulatory Scope and Overall Sanctions Architecture The Draft Decree applies to both domestic and foreign organizations and individuals engaging in crypto-related activities in Vietnam’s market. Covered entities include: (i) crypto asset issuers; (ii) crypto asset service providers, including trading platforms and market operators; (iii) Vietnamese and foreign investors participating in the pilot market; and (iv) other organizations involved in the offering, issuance, or provision of crypto-related services in Vietnam. The breadth of this scope is deliberate. It appears to reflect a regulatory view that cross-border structures, offshore platforms, and indirect participation may not necessarily insulate market actors from compliance obligations once they operate within the pilot framework. For the crypto industry, this may mark a shift from regulatory ambiguity toward a more explicit articulation of jurisdictional reach. At first glance, the Draft Decree’s monetary penalties appear restrained. The maximum fine per administrative violation is capped at VND 200 million (approx. USD 7,700) for organizations and VND 100 million (approx. USD 3,800) for individuals. However, focusing solely on fine levels risks missing the point. The Draft Decree also places great regulatory weight on supplementary sanctions and corrective measures, including: (i)
Read More