Vietnam: Government adopted Fintech Sandbox Decree (No. 94/2025/ND-CP) establishing mandatory registration for controlled testing of digital financial services

On 29 April 2025, the Government of Vietnam adopted Decree No. 94/2025/ND-CP, establishing a regulatory sandbox mechanism for the controlled testing of financial technology (fintech) solutions in the banking sector. Under the Decree, companies including Vietnamese fintech firms, credit institutions, and foreign bank branches must formally register and be certified by the State Bank of Vietnam (SBV) to participate in sandbox trials of eligible digital activities. These include credit scoring, data sharing via open APIs, and peer-to-peer (P2P) lending. Entities must submit a detailed application dossier comprising legal registration documents, a technical and risk management plan, and a testing proposal. Approval by the SBV is required before operations may begin. P2P lending firms are subject to additional restrictions, including a ban on foreign ownership and enhanced obligations regarding credit data reporting and customer protection. Participation is limited in scope, with a maximum duration of 2 years subject to possible extensions, and is restricted to application within the territory of Vietnam. Unauthorised digital financial activities outside the sandbox framework remain subject to existing legal prohibitions.