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 14, 2025
Interest in data center land acquisition has increased significantly over the past year, with a notable rise in inquiries from investors seeking to establish digital infrastructure in Thailand. Although the sector is still in its early stages, this emerging wave of development represents a significant shift in Thailand’s technology infrastructure landscape, driven primarily by multinational technology companies and operators looking to expand their regional presence. Project Development The data center sector in Thailand is attracting a diverse range of international investors, though with clear geographic patterns. Most investors are from China, Singapore, and Japan, with some additional interest from countries outside Asia, including the United States and Europe. This investor base consists primarily of multinational tech companies and operators seeking to establish new facilities rather than acquire existing assets. Data center business activities are also a sector promoted by Thailand’s Board of Investment (BOI), which offers investors both tax and nontax privileges as well as exemptions to foreign investment and land-ownership restrictions. Projects currently underway are still largely in the land acquisition and construction phase. Unlike more mature markets where many facilities are operational and generating revenue, the predominant focus in Thailand remains on securing suitable land and beginning the building process. This means that while interest is high and land assembly is accelerating, the sector as a whole has not yet reached the operational phase that will ultimately drive licensing applications and full regulatory compliance. The licensing process itself remains at an early stage, as most projects must first complete their facilities before applying for the specific licenses required from the telecommunications authority. Once the facilities are built, the next critical step will be obtaining these telecommunications licenses, which are mandatory for data center operations. Legal and Regulatory Considerations The complexity of data center development in Thailand requires
Read More
November 12, 2025
Thailand’s Customs Department has announced the cancellation of the longstanding de minimis exemption, which waives import duties on goods valued at THB 1,500 or less, as of January 1, 2026. This policy shift will directly impact e-commerce, logistics, and retail sectors, and will have wide-ranging implications for any company involved in cross-border trade with Thailand. Background Under current regulations, imported goods with a customs value (cost, insurance, and freight, or “CIF”) of THB 1,500 or less are exempt from import duties. This has been a cornerstone of the cross-border e-commerce model, allowing for the duty-free import of millions of small parcels. Under the new policy effective January 1, 2026, all imported goods, regardless of value, will be subject to assessment for import duties upon entry into Thailand. The stated rationale for this change is to create fair competition for Thai small and medium-sized enterprises (SMEs), which must pay VAT and other costs on their goods, putting them at a price disadvantage against foreign sellers who utilize the de minimis loophole. Business Implications This policy change will create new costs, compliance burdens, and operational challenges. For foreign e-commerce sellers and platforms: The most direct impact will be the addition of import duties to low-value items. Assuming the costs are passed on to the consumer, the higher prices and potentially more complex or slower customs clearance processes could lead to increased cart abandonment and reduced consumer demand. Businesses should review their pricing models and develop a clear strategy for calculating, declaring, and paying these new duties. For logistics providers and customs brokers: The administrative burden will be considerable. Carriers that previously handled millions of nondutiable parcels will now be required to process them for duty assessment and collection. This may necessitate new IT systems and streamlined processes to avoid delays at
Read More
November 7, 2025
Thailand and the United States signed a memorandum of understanding (MOU) titled “Cooperation to Diversify Global Critical Minerals Supply Chains and Promote Investments” on October 26, 2025, signaling a new strategic alignment aimed at developing Thailand’s mineral sector, particularly in rare earth elements (REEs). The MOU has implications for investments in technology, manufacturing, and other related sectors. This update outlines the key provisions of the MOU and the potential opportunities and legal navigating points for businesses. Objectives The primary driver of this agreement is the US initiative to diversify global supply chains for critical minerals and reduce reliance on current market leaders, particularly China. For Thailand, it represents a major opportunity to attract high-tech investment and develop its downstream processing industries. The cooperation is set to focus on five main areas: Technical knowledge: Exchange of technical expertise and international best practices to strengthen Thailand’s mining and processing sector. Joint cooperation: Establishing workshops, seminars, and scientific collaboration to boost innovation. Regulatory practice: Promoting good governance and streamlining regulatory and licensing procedures. Information sharing: Sharing data on potential projects and global market prices. Full-value chain: The MOU covers the entire mineral lifecycle, from exploration and extraction to processing, refining, and recycling. “First Opportunity to Invest” Clause The most debated provision within the MOU states that “participants expect to have the first opportunity to invest . . . in critical minerals assets that may be sold in Thailand.” Business implications: This clause is widely interpreted as granting US companies a first look or preferential access to investment opportunities in Thailand’s critical minerals sector. This could be a significant advantage for US-based or affiliated companies in mining, technology, and energy seeking to secure a foothold in a developing REE supply chain. Thai government position: Thai officials, including the prime minister, have publicly clarified
Read More
November 7, 2025
Tilleke & Gibbins has contributed the Vietnam chapter to the latest edition of the Global FinTech Guide published by Multilaw. The guide provides a comprehensive overview of the legal and regulatory framework governing financial technology across major jurisdictions around the world. Compiled by experienced practitioners from Multilaw member firms, the Global FinTech Guide examines how technological innovation is transforming financial services and how regulators are adapting to developments such as digital payments, virtual assets, and online financial platforms. The publication offers comparative insights into regulatory regimes and presents detailed, jurisdiction-specific analysis for companies, investors, and entrepreneurs active in the FinTech sector. The Vietnam chapter, prepared by lawyers in Tilleke & Gibbins’ technology, media, and telecommunications team, surveys the key legal and regulatory developments shaping the country’s FinTech ecosystem. It covers the following areas: 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 Distributed ledger technology (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 Thailand chapter to the Global FinTech Guide. The full guide is available on the Multilaw website.
Read More