Understanding Vietnamese Regulatory Sandboxes in Fintech

In the field of Fintech (financial technology), the terms sandbox and peer-to-peer lending model (P2P lending) often go together, especially in countries that are developing digital financial ecosystems. In Vietnam, the Government has recently issued Decree No. 94/2025/ND-CP regulating the controlled testing mechanism (sandbox) in the banking sector, for the implementation of new products, services, and business models through the application of technology solutions (called financial technology solutions), effective from July 1, 2025. Below, Viet An Law will help clients have a further understanding Vietnamese regulatory sandboxes in fintech.

What is the Regulatory Sandbox in Fintech?

“Regulatory Sandbox” is a controlled legal testing model that allows Fintech companies to deploy new financial products and services (such as e-wallets, peer-to-peer lending, blockchain, etc.) in a real environment but is closely monitored by a regulatory agency (usually the State Bank or the Securities Commission).

• Regulatory sandbox – “legal pilot framework” is a new and quite flexible approach in legislative technique, allowing direct, time-limited testing of innovations under regulatory supervision.
• Sandboxes allow for experimentation in a real-world environment, but with a defined scope and duration, along with appropriate safeguards to prevent any consequences of failure without overly impacting the national financial system.
• After the trial period, if the business starts up and operates successfully, it will have to exit the Sandbox legal framework and operate under the current legal framework.

In Vietnam, the sandbox has been applied in the financial sector with Decision No. 316/QD-TTg (2021) on piloting Mobile Money. The results show clear effectiveness, with 8.8 million customers using Mobile Money, of which 6.3 million customers are in remote areas. However, the sandbox is currently limited to the financial sector, but needs to be further expanded, especially in digital banking, peer-to-peer lending (P2P lending) and technology insurance.

Benefits of Regulatory Sandbox for Fintech

For business

• Businesses get to experiment with new ideas without having to comply with all the legal requirements of a formal financial company.
• Fintech businesses participating in the testing mechanism and sandbox allow for reducing barriers to entry for businesses with new products to promote faster, more efficient, and lower-cost market entry.
• Furthermore, applying the sandbox mechanism to good signals will enhance the brand value of the enterprise. This helps enterprises increase the trust of investors, thereby increasing the ability to access investment sources or funding from outside.
• Additionally, sandboxes can stimulate companies to expand partnerships in related fields or within the ecosystem.

For state management agencies

• Management agencies can monitor and evaluate the nature, processes, and potential risks of Fintech services, thereby issuing an official legal and management framework for this field.
• Sandboxes also help regulators engage in reforming existing regulations and increase the credibility and “friendliness” of state regulators to the market.

For the citizen

• Users can access innovative products in a safer environment.
• Limit the risks that may occur to customers when using Fintech solutions provided by organizations participating in the Testing Mechanism.

Officially building a controlled testing mechanism (Regulatory Sandbox) for Fintech activities in Vietnam

Recently, the Government issued Decree No. 94/2025/ND-CP regulating the regulatory sandbox in the banking sector, for the implementation of new products, services, and business models through the application of technological solutions (called financial technology solutions), effective from July 1, 2025. Specifically, as follows:

Fintech solutions are applied mechanism

Financial technology solutions (abbreviated as Fintech solutions) participating in testing at the Testing Mechanism include:

• Credit scoring: is a solution that applies information technology systems of credit institutions, foreign bank branches, and Fintech companies to score the credit reputation of an individual or organization to support credit granting decisions of credit institutions and foreign bank branches.
• Sharing data via open application programming interface (Open API): is a set of standardized APIs that can be used by computer systems of many credit institutions, foreign bank branches, Fintech companies and other third parties to send service requests to the credit institution system, foreign bank branches sharing that Open API.
• Peer-to-peer lending is an information technology application solution provided by a peer-to-peer lending company to connect information and support contract signing on a digital platform between customers who are borrowers and lenders.

Organizations participating in the mechanism

Organizations participating in the Testing Mechanism are credit institutions, foreign bank branches, and Fintech companies that have been granted a Certificate of Participation in the Testing Mechanism by the State Bank of Vietnam.

Testing time

The testing period for Fintech solutions is a maximum of 02 years, depending on each specific solution and field, calculated from the time the State Bank issues a Certificate of Participation in the Testing Mechanism.

The validity period of the Certificate of Participation in the Testing Mechanism shall not exceed the validity period (if any) of the Establishment License and Business Registration Certificate of the organization participating in the Testing Mechanism.

Testing space

The testing of Fintech solutions is limited to Vietnam territory, cross-border testing is not allowed.

Test range

• Organizations participating in the Testing Mechanism may only provide Fintech solutions within the scope specified in the Certificate of Participation in the Testing Mechanism;
• Depending on the Fintech solution and the specific proposal of the organization registering to participate in the Testing Mechanism in the Application for participation, the opinions of the ministries, the State Bank will decide the testing scope of the experimental Fintech solution in the Certificate of participation in the Testing Mechanism;
• Peer-to-peer lending companies participating in the Pilot Mechanism may not conduct other business activities not specified in the Certificate of Participation in the Pilot Mechanism, may not provide collateral for customer loans, act as a customer, or provide peer-to-peer lending solutions to pawnbrokers.

Registration and issuance of the Certificate of participation in the testing mechanism

To be granted a Certificate of Participation in the Testing Mechanism, it is necessary to meet the conditions and criteria for participating in the testing mechanism.

Organizations participating in the Testing Mechanism must prepare documents and carry out procedures to apply for a Certificate of participation in the Testing Mechanism at the State Bank according to specific instructions in Chapter II of Decree No. 94/2025/ND-CP.

Within 90 days from the date of being granted a Certificate of Participation in the Testing Mechanism by the State Bank, the organization granted a Certificate of Participation in the Testing Mechanism shall deploy Fintech solutions within the scope of the Certificate of Participation in the Testing Mechanism.

Certificate of Completion of Testing for Regulatory Sandbox

Pursuant to Clause 1, Article 21 of Decree No. 94/2025/ND-CP, the Certificate of completion of testing of organizations participating in the Testing Mechanism is issued by the State Bank in the following cases:

• When the official legal regulations for Fintech solutions have been completed and come into effect, the organizations participating in the Testing Mechanism will be granted a Certificate of Testing Completion by the State Bank and will comply with the legal regulations at the time of testing completion.
• When the implementation of the experimental Fintech solution by the organization participating in the Testing Mechanism is assessed as not violating current legal regulations and the Fintech solution is not considered a conditional business activity, the organization participating in the Testing Mechanism is granted a Certificate of Testing Completion by the State Bank and deployed to the market by legal regulations at the time of testing completion.

Accordingly, the organization participating in the Testing Mechanism sends the State Bank a dossier requesting the issuance of a Certificate of Testing Completion.

Above is the legal information on understanding Vietnamese Regulatory Sandboxes in Fintech. If Clients need legal advice on the operation of Fintech financial solutions, please contact Viet An Law for the best advice and support!