Required Documentation for Sandbox Registration Application in Vietnam

Sandbox is a controlled regulatory trial framework that allows Fintech companies to pilot new financial products and services (such as e-wallets, peer-to-peer lending, blockchain-based solutions, etc.) in a real-world environment under close supervision by competent authorities. Recently, the Government issued Decree 94/2025/ND-CP, which introduces the implementation of the Regulatory Sandbox Framework in the banking sector, applicable to certain Fintech solutions. To participate in this framework, enterprises are required to apply for and obtain a Certificate of Participation in the Regulatory Sandbox. Below, Viet An Law Firm provides legal consultation regarding the application dossier for participation in the sandbox, under the current legal provisions.

Fintech Solutions Eligible for Sandbox Registration Application

• According to Clause 2, Article 1 of Decree No. 94/2025/ND-CP, Fintech solutions eligible for participation in the regulatory sandbox in the banking sector include:
• Credit scoring;
• Data sharing via Open Application Programming Interface (Open API);
• Peer-to-peer (P2P) lending.

Specifically:

• Peer-to-peer (P2P) lending refers to a technology-based solution provided by a P2P lending company that facilitates the connection, information exchange, and execution of digital agreements between borrowers and lenders through an online platform. The currency used in P2P lending solutions must be Vietnamese Dong (VND).
• Open Application Programming Interface (Open API) refers to a standardized set of APIs that can be accessed and used by the computer systems of various credit institutions, foreign bank branches, Fintech companies, and other third parties to send service requests to the credit institutions or foreign bank branches that provide and share such Open APIs.
• Credit scoring is a solution that applies information technology systems of credit institutions, foreign bank branches, or Fintech companies to evaluate and assign creditworthiness scores to individuals or organizations, thereby assisting credit institutions and foreign bank branches in making lending decisions.

Legal and Administrative Principles for Sandbox Registration Application

The preparation and submission of the application dossier for participation in the regulatory sandbox must comply with the principles stipulated in Article 7 of Decree No. 94/2025/ND-CP, as follows:

• Language: The application dossier must be prepared in Vietnamese. In case any document is issued, notarized, or certified by a competent authority or organization of a foreign country, such document must be consularly legalized by Vietnamese law (unless exempt from consular legalization under applicable regulations), and must be translated into Vietnamese.
• Copies of documents: Copies included in the application dossier must be either certified true copies, copies issued from the original register, or copies presented together with the originals for verification, following legal requirements. For applications submitted via electronic means, the requirements shall follow the applicable regulations on electronic administrative procedures.
• Personal declaration form: The self-declared personal résumé must be signature-certified in accordance with the law.
• Submission methods: The application dossier may be submitted via:
  • Postal service (courier);
  • Direct submission to the One-Stop Service Division of the State Bank of Vietnam;
  • Online submission via the State Bank of Vietnam’s public service portal or the National Public Service Portal.

Required Documentation for Sandbox Registration Application in Vietnam

Regarding Open Application Programming Interface (Open API) solutions and credit scoring:

The application dossier for participation in the regulatory sandbox regarding Open Application Programming Interface (Open API) solutions and credit scoring, under Article 9 of Decree No. 94/2025/ND-CP, includes the following documents:

• Application for the Certificate of Participation in the Regulatory Sandbox: Using Form No. 01 (Appendix I) for credit institutions and foreign bank branches; Using Form No. 02 for Fintech companies.
• Documentation describing the organizational structure and governance during the deployment of the Fintech solution registered for testing.
• Resolution of the Members’ Council, Board of Directors, General Meeting of Shareholders, or written authorization from the competent representative of the owner, in accordance with the authority stipulated in the Charter, approving the proposal describing the Fintech solution registered for participation in the Regulatory Sandbox.
• Proposal describing the Fintech solution registered for participation in the Regulatory Sandbox: This document should include a simulation model or demonstration (Demo) of the solution, potential customer segments, and demonstrate full compliance with the criteria specified in Clause 1, Article 8, as detailed in Appendix II.
• Testing plan, including: The expected timeframe, location, and scope of testing; the estimated budget for testing activities; resources involved in the testing process; principles for communication and reporting to the State Bank of Vietnam during the testing phase; procedures for terminating the test, ensuring feasibility to complete all obligations within a maximum of six months from the date of the decision to cease testing.
• Personnel records: Personal declarations (not older than 6 months before submission); copies of diplomas and certificates proving the competence and professional qualifications of the legal representative, CEO (Director), Deputy CEO (Deputy Director), and key personnel responsible for implementing and testing the Fintech solution.
• Copies of documents proving the legal establishment and operation of the organization registering for the Regulatory Sandbox, including: establishment license or equivalent legal documents; charter; investment certificate of foreign investors (if any).

Required Documentation for Sandbox Registration Application – P2P Lending

The application dossier for participation in the Regulatory Sandbox mechanism for Fintech companies registering to test peer-to-peer lending solutions shall include the following specific documents as prescribed in Article 12 of Decree No. 94/2025/ND-CP:

• Application for participation: in accordance with Form No. 03, Appendix I.
• Document describing the organizational structure and management. Management, when implementing the peer-to-peer lending solution, registered for participation in the Regulatory Sandbox mechanism.
• Resolution of the Members’ Council, Resolution of the Members’ Council, Board of Directors, General Meeting of Shareholders, or a document from the authorized representative of the owner in accordance with the authority stipulated in the Charter approving the proposal describing the peer-to-peer lending solution registered for participation in the Regulatory Sandbox mechanism.
• Proposal describing the peer-to-peer lending solution. The proposal describing the peer-to-peer lending solution is registered for participation in the Regulatory Sandbox mechanism, as specifically guided in Appendix III.
• Testing plan, including: the expected timeframe, location, and scope of testing; the estimated budget for testing activities; the resources anticipated to participate in the testing; and the principles for communication and reporting to the State Bank of Vietnam during the testing phase; procedures for terminating the test to ensure feasibility in fulfilling all obligations to customers and related parties after the decision to cease testing is made.
• Personnel records: Personal declarations, judicial record extracts (not older than 6 months prior to submission), copies of diplomas and certificates proving the competence and professional qualifications of the legal representative, CEO (Director); a document from the authorized representative of the organization where the legal representative, CEO (Director) has or is currently working, confirming the position and duration of tenure, or a copy of the document proving the position and duration of tenure at the organization.
• Copies of documents proving that the Fintech Company is legally established and operating, including: establishment license or equivalent legal documents; charter.

Notes on filling out the Application for Granting the Certificate of Participation

• Provide complete information of the organization applying for the Certificate of Participation in the Regulatory Sandbox mechanism: Name (in Vietnamese / English (if any) / Trading name (if any)); Establishment license / Enterprise registration certificate (number / issuing authority/date of issue); Enterprise code / Tax code; Address of the head office, telephone number, fax number, email; Legal representative(s) (if there are multiple legal representatives, list all); …
• Fintech solution participating in the Regulatory Sandbox mechanism: Open Application Programming Interface (Open API) / Credit scoring / Peer-to-peer lending.
• Clearly state the commitments and responsibilities of the organization.
• All documents attached to the application must be numbered and referenced in the application form.
• In case the dossier is sent by postal service or submitted directly to the One-Stop Shop of the State Bank of Vietnam, the organization applying for participation in the Regulatory Sandbox mechanism shall submit 02 sets of dossiers and 06 CDs (or 06 USB drives) containing scanned copies of the complete dossier requesting the Certificate of Participation in the Regulatory Sandbox mechanism.

The above is the guidance on the required documentation for the sandbox registration application in Vietnam. If you require legal consultation or assistance in carrying out the procedures for obtaining the Certificate of Participation in the sandbox, please contact Viet An Law for the best support and legal services!