1. What is Fintech? What are the characteristics of fintech solutions?

Fintech (short for finance and technology) is understood as the application of modern and innovative technologies in the financial and banking sector. Fintech refers to tools and means through which licensed organizations may provide financial solutions that are more transparent, efficient, convenient, and cost-effective than traditional financial services, such as payment services, money transfers, peer-to-peer lending, asset management, and similar services (collectively referred to as fintech solutions).

As fintech solutions are innovative financial solutions, they generally possess the following fundamental characteristics: (i) the law does not yet provide specific and clear regulations; (ii) they are innovative and generate benefits and added value; and (iii) mechanisms for management and risk control have been designed.

Thus, although fintech solutions have notable advantages in terms of innovation and the potential to generate significant benefits, they also entail various risks. For this reason, on April 29, 2025, the Government promulgated Decree No. 94/2025/ND-CP on the regulatory sandbox mechanism in the banking sector (effective from July 1, 2026), which aims to control the implementation of fintech solutions. This mechanism is established to simultaneously achieve the following objectives:

• Promoting innovation and modernization in the banking sector, thereby contributing to the realization of financial inclusion in a transparent, convenient, safe, and cost-efficient manner;
• Establishing a testing environment to assess the risks, costs, and benefits of fintech solutions, while supporting the development of solutions that are compatible with market demands and the legal framework;
• Limiting risks to customers when using fintech products and services; and
• Providing a practical basis for competent state authorities to study, formulate, and improve the relevant legal framework in the future.

2. What is a fintech company? Which entities are permitted to provide fintech solutions within the regulatory sandbox framework in Vietnam?

Currently, the entities permitted to provide fintech solutions within the regulatory sandbox framework in Vietnam include:

• Credit institutions;
• Branches of foreign banks;
• Fintech companies (financial technology companies).

Để làm rõ, công ty fintech được định nghĩa là:

For clarification, a fintech company is defined as:

• An organization that is not a credit institution or a branch of a foreign bank;
• Having a valid establishment license or business registration in Vietnam;
• Providing fintech solutions to the market either (i) independently; or (ii) through cooperation with credit institutions or branches of foreign banks.

Accordingly, a fintech company may be simply understood as an enterprise that provides fintech solutions, namely financial services applying new technologies, rather than directly operating as a traditional bank.

3. Which fintech solutions are eligible to participate in the regulatory sandbox mechanism?

According to Article 1.2 of Decree No. 94/2025/ND-CP, three fintech solutions are currently subject to the regulatory sandbox mechanism, including:

• Credit scoring: A solution that applies information technology systems to assess the creditworthiness of an individual or organization in order to support lending decisions of credit institutions and branches of foreign banks.
• Data sharing through Open Application Programming Interfaces (Open API): An Open API is a set of standardized API that may be used by the computer systems of multiple credit institutions, branches of foreign banks, fintech companies, and other third parties to send service requests to the systems of credit institutions or branches of foreign banks that provide such Open API.
• Peer-to-peer lending (P2P lending): A solution applying information technology to connect information and facilitate the conclusion of contracts on a digital platform between customers acting as borrowers and lenders.

4. Conditions, dossier, and procedures for registration to participate in the regulatory sandbox mechanism for fintech solutions on credit scoring and Open API sharing

4.1. Conditions for participation

Entities as listed in Section 2 of this article may be considered for participation in the regulatory sandbox mechanism for fintech solutions on credit scoring and Open API sharing if they satisfy the following conditions:

For credit institutions and branches of foreign banks:

• They must not be subject to special control under the Law on Credit Institutions;
• The fintech solution proposed for participation in the sandbox must satisfy the following criteria:
• It is a solution involving technical and operational contents for which the current legal framework does not yet provide specific and clear guidance for implementation and application;
• It is an innovative solution that provides benefits and added value to users of services in Vietnam, particularly solutions that support and promote the objective of financial inclusion;
• It has established and developed a risk management framework to limit adverse impacts on the banking system and banking, monetary, and foreign exchange activities; it has also developed plans to handle and remedy risks arising during the testing process, as well as measures to protect consumer rights;
• The solution has been reviewed and fully evaluated by the participating organization in terms of its operational aspects, functions, utility, and usefulness;
• The solution demonstrates feasibility for provision to the market after the completion of the testing process.

For fintech companies:

• The fintech solution must meet the same criteria applicable to credit institutions and branches of foreign banks;
• The company must be a legal entity lawfully established and operating in the territory of Vietnam, and must not be undergoing division, separation, consolidation, merger, conversion, dissolution, or bankruptcy in accordance with the law;
• The legal representative and the General Director (Director) must hold at least a bachelor’s degree in one of the following fields: economics, business administration, law, or information technology, and must have at least 02 years of experience as a manager or executive of an organization in the financial or banking sector, and must not fall within the categories of persons prohibited under the law.

Note: Organizations registering to participate in the regulatory sandbox mechanism are responsible for ensuring that these conditions continue to be satisfied throughout the entire participation period.

4.2. Application dossier for participation

• The application dossier for participation in the regulatory sandbox mechanism for fintech solutions on credit scoring and Open API sharing includes the following documents:
• An application for issuance of a Certificate of participation in the regulatory sandbox mechanism;
• Documents describing the organizational structure and management arrangements for the implementation of the fintech solution proposed for testing;
• A resolution of the Members’ Council, the Board of Directors, the General Meeting of Shareholders, or a written approval from the competent representative of the owner in accordance with the authority prescribed in the Charter, approving the proposal describing the fintech solution to be registered for participation in the sandbox mechanism;
• A proposal describing the fintech solution registered for participation in the sandbox mechanism, including a simulation model of the solution or a demonstration version (demo); the potential customer group; and evidence demonstrating full compliance with the prescribed criteria;
• A testing plan, including: the expected testing period, location, and scope; the estimated budget for testing activities; resources involved in the testing; principles for communication and reporting to the State Bank of Vietnam during the testing period; and a plan for termination of the testing ensuring feasibility to fulfill all obligations within a maximum period of 06 months from the date of the decision to terminate the testing;
• Personnel documents, including: curriculum vitae (issued no more than 06 months prior to the submission date), copies of diplomas evidencing the qualifications and professional expertise of the legal representative, the General Director (Director), Deputy General Director (Deputy Director), and other key personnel responsible for implementing the fintech solution testing;
• Copies of documents evidencing that the applying organization has been lawfully established and operates legally, including: the establishment license or equivalent document; the company charter; and the investment certificate of a foreign investor (if any).

4.3. Registration procedures for participation

The procedures for registration to participate in the regulatory sandbox mechanism for fintech solutions on credit scoring and Open API sharing are as follows:

Step 1: Submission of application

The applying organization submits 02 sets of application dossiers together with 06 electronic copies (CD/USB) containing scanned versions of the full dossier as listed in Section 4.2 of this article to the State Bank of Vietnam, either directly or by post.

Step 2: Receipt and review of the dossier

Within 05 working days, the State Bank of Vietnam will issue one of the following notifications:

• Confirmation that the dossier is valid; or
• A request for supplementation or completion of the dossier.

Note: Within 05 working days from the date of the request for supplementation or completion of the dossier, if the applying organization fails to resubmit the dossier or if the supplemented dossier does not meet the required components, the State Bank of Vietnam will return the dossier.

Step 3: Appraisal of the dossier

Within 90 working days from the date of issuing the written confirmation of receipt of a complete and valid dossier, the State Bank of Vietnam, in coordination with relevant ministries, will conduct an appraisal of the dossier, including on-site inspections where necessary.

Step 4: Licensing decision

After the appraisal period concludes, the State Bank of Vietnam shall issue a Certificate of participation in the regulatory sandbox mechanism to the applying organization whose dossier satisfies the prescribed conditions and criteria. In case of refusal, the State Bank of Vietnam shall provide a written response stating the reasons.

Step 5: Implementation of the testing

Within 90 days from the date of issuance of the Certificate of participation in the regulatory sandbox mechanism, the certified organization shall commence the implementation of the fintech solution within the scope permitted under the certificate.

5. Conditions, dossier, and procedures for registration to participate in the regulatory sandbox mechanism for fintech solutions on peer-to-peer lending

5.1. Conditions for participation

Entities as listed in Section 2 of this article may be considered for participation in the regulatory sandbox mechanism for fintech solutions on peer-to-peer lending if they satisfy the following conditions:

For credit institutions and branches of foreign banks:

• They must not be subject to special control under the Law on Credit Institutions;
• The fintech solution proposed for participation in the sandbox must satisfy the following criteria:

+ It is a solution involving technical and operational contents for which the current legal framework does not yet provide specific and clear guidance for implementation and application;

+ It is an innovative solution that provides benefits and added value to users of services in Vietnam, particularly solutions that support and promote the objective of financial inclusion;

+ It has established and developed a risk management framework to limit adverse impacts on the banking system and banking, monetary, and foreign exchange activities; it has also developed plans to handle and remedy risks arising during the testing process, as well as measures to protect consumer rights;

+ The solution has been reviewed and fully evaluated by the participating organization in terms of its operational aspects, functions, utility, and usefulness;

+ The solution demonstrates feasibility for provision to the market after the completion of the testing process;

+ Measures are in place to determine and manage the maximum outstanding loan balance for each borrower using the peer-to-peer lending solution, and to report and access real-time borrower information from the National Credit Information Center of Vietnam (CIC) to ensure compliance with regulations on the maximum outstanding loan balance applicable to each borrower under the peer-to-peer lending solution provided as well as across all peer-to-peer lending solutions participating in the sandbox mechanism;

+ Disbursement and repayment of loans, interest, and fees for customer transactions under the peer-to-peer lending solution must be conducted through the customer’s payment account at a credit institution or branch of a foreign bank, or through the customer’s e-wallet at a payment intermediary service provider;

+ Measures are in place to ensure that the term of the contract between the borrower and the lender using the peer-to-peer lending solution participating in the sandbox mechanism does not exceed 02 years.

For fintech companies:

• The fintech solution must satisfy the same criteria applicable to credit institutions and branches of foreign banks;
• The company must be an enterprise lawfully established and operating in the territory of Vietnam; it must not be a foreign-invested enterprise, and must not be undergoing division, separation, consolidation, merger, conversion, dissolution, or bankruptcy in accordance with the law;
• The legal representative and the General Director (Director) of the company must be Vietnamese nationals; must have no criminal record; must not have been administratively sanctioned in the fields of finance, banking, or cybersecurity; must not concurrently be the owner or manager of enterprises providing financial or banking services, pawn services, or multi-level marketing businesses; and must not be the owner of informal rotating savings schemes (hui, ho, bieu, phuong), nor currently serve as a member of the Board of Directors, Members’ Council, Supervisory Board, General Director (Director), Deputy General Director (Deputy Director), or equivalent positions in a credit institution, branch of a foreign bank, or a payment intermediary service provider;
• The legal representative and the General Director (Director) of the company must hold at least a bachelor’s degree in one of the following fields: economics, business administration, law, or information technology, and must have at least 02 years of experience as a manager or executive in an organization operating in the financial or banking sector, and must not fall within the categories of persons prohibited under the law;
• The company must meet standards regarding human resources, infrastructure, and technical facilities for the digital platform implementing the peer-to-peer lending solution, ensuring at least the following minimum requirements:

+ Information technology systems and data storage systems must be located within the territory of Vietnam, operate safely and continuously, and have independent backup systems separate from the primary systems to ensure uninterrupted operation in the event of incidents, particularly technical or technological failures;

+ Data and information of all customers and related parties must be updated, stored, and shared on a digital platform with a high level of security, ensuring transparency among participating parties while maintaining confidentiality of participants’ information from unrelated parties in accordance with the law;

+ Information technology systems must be tested and evaluated before being put into operation;

+ Technical personnel must possess professional qualifications appropriate to their responsibilities to ensure the system operates safely and continuously.

Note: Organizations registering to participate in the regulatory sandbox mechanism are responsible for ensuring that these conditions continue to be satisfied throughout the entire participation period.

5.2. Application dossier for participation

The application dossier for participation in the regulatory sandbox mechanism for fintech solutions on peer-to-peer lending includes the following documents:

• An application for participation in the regulatory sandbox mechanism;
• Documents describing the organizational structure and management arrangements for the implementation of the peer-to-peer lending solution proposed for participation in the sandbox mechanism;
• A resolution of the Members’ Council, the Board of Directors, the General Meeting of Shareholders, or a written approval from the competent representative of the owner in accordance with the authority prescribed in the Charter, approving the proposal describing the peer-to-peer lending solution to be registered for participation in the sandbox mechanism;
• A proposal describing the peer-to-peer lending solution registered for participation in the sandbox mechanism;
• A testing plan, including: the expected testing period, location, and scope; the estimated budget for testing activities; the expected resources participating in the testing; principles for communication and reporting to the State Bank of Vietnam during the testing period; and arrangements for termination of the testing to ensure feasibility in fulfilling obligations to customers and related parties after the issuance of a decision to terminate the testing;
• Personnel documents, including: curriculum vitae, judicial record certificates (issued no more than 06 months prior to the submission date), copies of diplomas evidencing the qualifications and professional expertise of the legal representative and the General Director (Director); a written confirmation from the competent representative of the organization where the legal representative or General Director (Director) has worked or is currently working, certifying the position held and the duration of holding such position, or copies of documents evidencing the position and duration of holding such position within the organization;
• Copies of documents evidencing that the fintech company has been lawfully established and operates legally, including: the establishment license or equivalent document and the company charter.

5.3. Registration procedures for participation

The procedures for registration to participate in the regulatory sandbox mechanism for fintech solutions on peer-to-peer lending are as follows:

Step 1: Submission of application

The applying organization submits 02 sets of application dossiers together with 06 electronic copies (CD/USB) containing scanned versions of the full dossier as listed in Section 5.2 of this article to the State Bank of Vietnam, either directly or by post.

Step 2: Receipt and review of the dossier

Within 05 working days, the State Bank of Vietnam will issue one of the following notifications:

• Confirmation that the dossier is valid; or
• A request for supplementation or completion of the dossier.

Note: Within 05 working days from the date of the request for supplementation or completion of the dossier, if the applying organization fails to resubmit the dossier or if the supplemented dossier does not meet the required components, the State Bank of Vietnam will return the dossier.

Step 3: Appraisal of the dossier

Within 90 working days from the date of issuing the written confirmation of receipt of a complete and valid dossier, the State Bank of Vietnam, in coordination with relevant ministries, will conduct an appraisal of the dossier, including on-site inspections where necessary.

Step 4: Licensing decision

After the appraisal period concludes, the State Bank of Vietnam shall issue a Certificate of participation in the regulatory sandbox mechanism to the applying organization whose dossier satisfies the prescribed conditions and criteria. In case of refusal, the State Bank of Vietnam shall provide a written response stating the reasons.

Step 5: Implementation of the testing

Within 90 days from the date of issuance of the Certificate of participation in the regulatory sandbox mechanism, the certified organization shall commence the implementation of the fintech solution within the scope permitted under the certificate.