On 29 April 2025, the Government of Vietnam issued Decree No. 94/2025/ND-CP (“Decree 94”), establishing a controlled testing environment or “Regulatory Sandbox” for Fintech solutions in the banking sector. Effective from 1 July 2025, Decree 94 allows credit institutions, foreign bank branches, and Fintech companies to pilot innovative products under the supervision of the State Bank of Vietnam (“SBV”). The initiative aims to foster financial innovation and inclusion while mitigating risks associated with emerging technologies.
The primary objectives of the Regulatory Sandbox are
- to stimulate innovation in the Vietnamese banking and financial sector;
- enhance financial inclusion by supporting accessible and efficient services; and
- allow both regulators and industry players to better understand the risks and benefits of emerging Fintech solutions.
Below are the key features and notable provisions of Decree 94:
1. Establishment of a Controlled Testing Environment (Regulatory Sandbox)
Decree 94 introduces a regulatory sandbox framework in Vietnam, allowing eligible entities to test Fintech innovations in a controlled environment for a period of up to two years, with possible extensions. Testing is confined to Vietnam and is subject to SBV supervision. The sandbox provides a legal foundation for piloting new technologies prior to full-scale deployment, facilitating regulatory feedback and making iterative improvements.
2. Eligible Fintech Solutions for Testing
Fintech solutions initially permitted to participate in the sandbox include:
- Credit Scoring Solutions: Technologies aimed at assessing the creditworthiness of individuals or organizations.
- Data Sharing via Open Application Programming Interfaces (Open APIs): Solutions enabling secure data exchange between banks and third-party providers, based on customer consent.
- Peer-to-Peer (P2P) Lending Platforms: Platforms that directly connect lenders with borrowers, bypassing traditional intermediaries.
3. Eligible Participants and Entry Criteria
Entities eligible to participate in the sandbox include:
- Credit institutions not under special control;
- Foreign bank branches; and
- Fintech companies legally established in Vietnam.
Applicants must demonstrate that their solutions promote financial inclusion, offer clear consumer benefits, and incorporate robust risk management and consumer protection frameworks. Fintech companies are required to meet specific qualifications, including:
- Legal compliance and operational capability;
- An established track record;
- Leadership with relevant academic qualifications and a minimum of two years of management experience in finance, banking, or technology; and
- High internal feasibility and potential for post-sandbox commercialization.
4. Specific Regulations and Enhanced Scrutiny for Peer-to-Peer (P2P) Lending
Decree 94 imposes strict requirements for P2P lending solutions in the Regulatory Sandbox, mandating operational safeguards like managing maximum loan exposure per borrower, utilizing National Credit Information Centre (CIC) data, processing transactions through bank accounts or licensed e-wallets, and limiting loan terms to two years. Fintech companies must be wholly Vietnamese-owned, with legal representatives and CEOs undergoing rigorous background checks (no criminal record or penalties, no conflicting roles), and their IT systems must be Vietnam-based, meeting high standards for security, privacy, continuity, and pre-operational testing.
5. Application, Approval, and Operational Process
Organizations applying to participate in the Regulatory Sandbox must submit a detailed dossier to the SBV, including an application form, Fintech solution description, testing plan, risk management protocols, personnel qualifications, and legal establishment documents. The SBV reviews applications, may consult other agencies or conduct on-site inspections, and issues a Certificate of Participation outlining the approved solution, testing scope, duration, and conditions, with testing required to start within 90 days.
6. Operational Limitations and Supervisory Oversight
Sandbox testing must be conducted entirely within Vietnam—cross-border testing is prohibited. Participants are restricted to the activities approved under their Certificate of Participation. For example, P2P lending firms may not provide loan guarantees or engage in unrelated services. Regular reporting and compliance monitoring by the SBV are mandatory throughout the testing period.
Future Implications
The practical experiences and data gathered from the Regulatory Sandbox will serve as a crucial empirical basis for the SBV and other relevant authorities to consider in developing or refining the broader legal and regulatory framework governing Fintech activities in Vietnam.
The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.
