Tiếng Việt
中文 (中国)
日本語
Effective July 1, 2025, Decree No. 94/2025/ND-CP issued by the Government of Vietnam marks a pivotal regulatory milestone for the growth of innovative financial solutions in the country. With the introduction of a regulatory sandbox, Vietnam officially establishes its first legal framework for testing new Fintech models under controlled conditions, enabling risk assessment and policy refinement.
This reflects a notable governmental effort to balance innovation promotion with financial system safety and consumer protection.
Scope of Pilot Program and Applicable Entities
Under Decree 94/2025/ND-CP, the sandbox will apply to three key areas: peer-to-peer lending (P2P lending), credit scoring, and data sharing via open application programming interfaces (Open APIs). However, participation is not open to all. For the high-risk P2P lending sector, only Fintech companies based in Vietnam and without oversea investment are eligible for sandbox registration. Licensed credit institutions may participate but are restricted to specific approved areas.
Participation comes with strict legal obligations. Companies must submit a comprehensive application, demonstrate operational capacity, commit to consumer protection, implement risk management mechanisms, and ensure that their operations do not threaten financial system stability during the trial period.
Summary of Permitted Sandbox Activities
| Solution/Topic | Description |
| Credit Scoring | +) A technology-based tool used by credit institutions or Fintech companies to evaluate the creditworthiness of individuals or entities. +) This tool assists in the assessment and approval of credit applications. |
| Data Sharing via Open API | +) A standardized interface enabling interaction between software systems, used by credit institutions, Fintech companies, and third parties. +) APIs allow third parties to submit service requests to institutions with Open API access. |
| P2P Lending | +) A technology platform operated by a Fintech company (a P2P lending provider) that connects and facilitates lending between borrowers and lenders through an electronic interface. +) All P2P lending transactions must be conducted in Vietnamese Dong (VND). |
Sandbox Operation: Licensing, Supervision, and Limitations
To participate in the regulatory sandbox, applicants must obtain a “Controlled Trial Certificate” from the State Bank of Vietnam (SBV). Approval is based on criteria including the level of innovation, potential for application, risk control capacity, and absence of adverse market impact.
The maximum trial duration is two years, extendable under exceptional circumstances. Throughout this period, participating entities must adhere to strict reporting and disclosure requirements and remain under regulatory supervision. Should violations or systemic risks arise, the SBV retains the authority to suspend or revoke the certificate.
Legal Perspectives: Opportunities and Risks to Note
From a legal standpoint, the regulatory sandbox presents several important opportunities. First, it provides Fintech enterprises with a structured environment to test innovative ideas and refine their business models before full-scale deployment.
It also enables collaboration between traditional banks and Fintech firms—an inevitable trend in the evolution of digital finance. Notably, the sandbox legitimizes business models not yet regulated under existing laws, paving the way for future legal and policy development.
However, the sandbox comes with considerable legal risks and limitations. Foreign-invested enterprises—including those with indirect ownership—face significant restrictions, particularly in the P2P lending sector.
Participants must also prioritize legal compliance concerning user data protection and operational risk management. Regulatory violations could lead to certificate revocation, adversely affecting a company’s reputation, finances, and business continuity.
Legal Recommendations from ASL LAW
To make the most of the sandbox opportunity, ASL LAW recommends that Fintech companies take proactive and comprehensive steps from the outset:
- Conduct a legal review of the business model to ensure alignment with eligible sandbox activities and regulatory conditions.
- Develop an internal legal framework encompassing risk control mechanisms, data privacy policies, and procedures for handling consumer complaints and feedback.
- Establish a secure and compliant technological infrastructure compatible with the SBV’s monitoring systems.
- Seek legal counsel with deep expertise in Fintech and banking law to support the application process, facilitate dialogue with regulators, and ensure full compliance throughout the pilot period.
Conclusion
The regulatory sandbox is a major step forward, creating a “window of opportunity” for Fintech companies to experiment and launch financial solutions tailored to market needs. However, turning opportunity into reality requires more than technical innovation—it demands legal readiness from day one.
With extensive experience in financial, banking, and digital technology advisory, ASL LAW is committed to supporting businesses throughout their trial, development, and transition into the future of finance.
ASL Law is a leading full-service and independent Vietnamese law firm made up of experienced and talented lawyers. ASL Law is ranked as the top tier Law Firm in Vietnam by Legal500, Asia Law, WTR, and Asia Business Law Journal. Based in both Hanoi and Ho Chi Minh City in Vietnam, the firm’s main purpose is to provide the most practical, efficient and lawful advice to its domestic and international clients. If we can be of assistance, please email to [email protected].
ASL LAW is the top-tier Vietnam law firm for Banking & Financial Services. If you need any advice, please contact us for further information or collaboration.
