What is Open API Data Sharing in Vietnam?

In the context of the strong digital transformation of the current 4.0 revolution, numerous financial technology solutions (Fintech solutions) have emerged, including credit scoring, data sharing via open application programming interfaces (Open APIs), and peer-to-peer lending (P2P Lending). One of the important solutions being applied by many countries and organizations is data sharing via open application programming interface (Open API). What is open API Data sharing in Vietnam? Viet An Law will find out with clients in the article below.

What is an Open API?

API stands for Application Programming Interface, which means an application programming interface. This is an interface that allows communication between software applications within an organization or between organizations (according to Clause 1, Article 3 of Circular 64/2024/TT-NHNN).

Pursuant to Clause 2, Article 3 of Circular 64/2024/TT-NHNN:

“Open API (open application programming interface in the banking industry) is a set of APIs provided by the Bank to third parties to directly connect and process data to provide services to customers. Open API includes: Basic Open API and other Open APIs.”

At the same time, Clause 5, Article 3 of Decree 94/2025/ND-CP also stipulates:

“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 system of credit institutions and foreign bank branches sharing that Open API.”

Thus, it can be understood that an Open API (Application Programming Interface) is a standard or protocol that enables different applications and systems to interact and communicate with each other effectively. The Open API is designed to allow third parties to access and integrate with the system without needing to understand the internal installation details.

What is open API Data sharing in Vietnam?

Open API Data sharing is one of the financial technology solutions (abbreviated as Fintech solutions) participating in controlled testing in the banking sector for the implementation of new products, services, and business models through the application of technology solutions according to Point b, Clause 2, Article 1 of Decree 94/2025/ND-CP.

Thus, it can be understood: Open API Data sharing (Open API) is one of the Fintech financial technology solutions, allowing different systems and software to access and use each other’s data or services through a set of standardized APIs, which 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 branch sharing that Open API.

What are the benefits of Open API Data sharing?

Open APIs bring many important benefits to developers and businesses, including:

• Increased connectivity: Open APIs allow applications to connect and exchange data easily, helping to create rich ecosystems and seamless integration between different services.
• Cost and time savings: Using Open APIs helps reduce the time and cost of developing and maintaining applications, because developers can take advantage of existing APIs instead of building from scratch.
• Promote innovation: Open API opens up opportunities for creativity and innovation by allowing external developers to contribute and create new services based on existing APIs.

However, Open API is a new field in both technical and legal aspects, not only in Vietnam but also in the world. The challenges and difficulties in implementing Open API are not only technological issues but also changes in perception and changes in the legal framework.

What does the basic Open API list include?

Based on Article 6 of Circular 64/2024/TT-NHNN, the basic Open API list is organized into the following groups:

Open API to query information on exchange rates and interest rates of banks includes:

• API to get interest rate information;
• API to get exchange rate information;

Open API to query customer information includes:

• API to confirm and get customer consent;
• API to get access code;
• API to refresh access code;
• API to revoke access code;
• API to get list of accounts;
• API to get account information;
• API to get transaction history.

Open API for initiating payments, depositing money into e-wallets, and withdrawing money from e-wallets includes:

• Open API for initiating payments includes: API for Initiating Payments, API for Confirming Customer Redirect Flow, API for Getting Access Codes in Redirect Flow. API for Updating Payment Confirmation Status of Decoupled Flow Customers, API for Confirming Payments, API for Getting Transaction Status, API for Getting Payment Confirmation Status of Decoupled Flow Customers;
• Open API to deposit money into e-wallet, including: API to deposit e-wallet, API to confirm OTP, API to update the confirmation status of e-wallet deposit of customers in Decoupled stream, API to get the confirmation status of e-wallet deposit of customers in Decoupled stream, API to confirm e-wallet deposit, API to get transaction status.
• Open API to withdraw money from the e-wallet.

Signing contracts and publicizing Open API information

According to Article 8 and Article 9 of Circular 64/2024/TT-NHNN, the Bank must sign a contract with a third party on the implementation of Open API. Before officially connecting and processing data with a third party, the Bank must publicize Open API information on the Bank’s official website, including at least the following contents:

• Information about the Open API testing system.
• List of open APIs deployed by the Bank.

Deploying the Pilot Mechanism for open API Data sharing

Open API Data sharing is one of the financial technology solutions participating in the controlled pilot regime in the banking sector, according to Decree 94/2025/ND-CP, specifically as follows:

Testing time, space, and scope

• Testing period: maximum 02 years from the date the State Bank issues the Certificate of Participation in the Pilot Mechanism, and can be extended.
• Testing space: The testing is limited to the territory of Vietnam; cross-border testing is not allowed.
• Testing scope: Organizations participating in the Testing Mechanism are only allowed to provide Fintech solutions within the scope specified in the Certificate of Participation in the Testing Mechanism.

Conditions and procedures for registering for a Certificate of Participation in the Testing Mechanism

To participate in the testing mechanism, it is necessary to apply for a Certificate of Participation in the Testing Mechanism.

Conditions: Conditions of the Open API solution and conditions of organizations participating in the testing mechanism according to Article 8 of Decree 94/2025/ND-CP.

Application for participation in the pilot mechanism: according to Article 9 of Decree 94/2025/ND-CP.

Procedures for registration to participate in the pilot mechanism:

• Organizations participating in the pilot mechanism send their application by post (postal service) or submit it directly to the State Bank’s One-Stop Department or online at the State Bank’s Public Service Portal or the National Public Service Portal.
• Within 05 working days from the date of receiving the dossier, the State Bank shall issue a written confirmation of receipt of the complete and valid dossier or a written request for the organization registering to participate in the Testing Mechanism to supplement and complete the dossier components. The time for supplementing and completing the dossier components shall not be included in the dossier appraisal time.
• Within 90 working days from the date of sending the written confirmation of receipt of the complete and valid dossier components, the State Bank shall coordinate with relevant ministries to conduct dossier appraisal, including on-site inspection if necessary.
• Upon receiving a complete and valid dossier, the State Bank shall send a written request to the relevant ministries for comments. Within 15 working days from the date the State Bank issues a written request, the relevant ministries shall send the State Bank a written request for comments on the dossier.
• After the prescribed appraisal period ends, the State Bank shall issue a Certificate of Participation in the Testing Mechanism to the organization registering to participate in the Testing Mechanism whose dossier meets the conditions and criteria. In case of refusal, the State Bank shall respond in writing and state the reasons.

Above is advice on: what is open API Data sharing in Vietnam? If clients have any related questions or need legal advice on financial technology (Fintech) solutions and P2P Lending, please contact Viet An Law for the best advice and support!