Vietnam’s government has issued Decree No. 94/2025/ND-CP, which comes into effect on July 1, 2025, establishing a regulatory sandbox for testing new financial technology (Fintech) products, services, and business models within the banking sector. However, companies are not permitted to trial their solutions outside Vietnamese territory.

Under the decree, Fintech solutions will be allowed to participate in a controlled testing environment for a maximum of two years, depending on the specific solution and field, starting from the date the State Bank of Vietnam grants a Certificate of Participation.

The sandbox aims to promote innovation and modernization in the banking sector, contributing to financial inclusion for both individuals and businesses. The goal is to provide transparent, convenient, safe, and cost-effective financial access through modern technological applications.

Results from sandbox trials will serve as practical references for regulatory agencies in evaluating and potentially developing or revising related legal frameworks.

Eligible Fintech solutions and participants

The decree outlines several Fintech categories eligible for testing, including credit scoring, open application programming interface (Open API) data sharing, and peer-to-peer (P2P) lending.

Applicable participants include credit institutions, foreign bank branches (as defined under the Law on Credit Institutions), Fintech companies, state regulatory bodies, customers, and other relevant individuals or organizations.

The selection process for sandbox participation must be transparent, with clearly defined eligibility criteria and assessment procedures. However, participation in the sandbox does not imply that an entity meets the legal conditions for full commercial operation or investment under existing laws.

Strict boundaries for testing

The decree strictly limits Fintech testing activities to within Vietnam. Cross-border implementation is not permitted. Entities participating in the sandbox may only offer solutions within the scope defined in the Certificate of Participation issued by the State Bank of Vietnam.

For example, P2P lending companies may only provide services within the boundaries and scope approved in their certificate. These companies are also prohibited from engaging in other business activities, providing loan guarantees to customers, acting as borrowers themselves, or offering P2P lending services to pawn businesses.

The central bank will determine the testing scope for each Fintech solution as outlined in the participation certificate.

Tuan Nguyen