The Government has recently enacted Decree No. 94/2025/ND-CP, which governs the controlled regulatory sandbox within the banking sector, facilitating the deployment of new products, services, and business models utilising financial technology (Fintech) in a secure, transparent, and restricted testing environment via the application of technology solutions. 

1. The subject of application

The financial technology solutions (hereby “Fintech solutions”) involved in the Testing Mechanism encompass: (i) Credit scoring; (ii) Data sharing through open application programming interface (Open API), and (iii) Peer-to-peer (P2P) lending. 

2. The objective of fintech regulatory sandbox

• The Decree states that the purpose of the regular sandbox is to foster innovation and modernisation within the banking sector, thereby achieving the objective of financial universalisation for individuals and enterprises in a transparent, convenient, secure, efficient, and cost-effective manner. The testing environment facilitates the evaluation of risks, costs, and advantages associated with Fintech solutions, so providing management agencies with a practical foundation to formulate or amend pertinent regulatory laws as needed. 

• The outcomes of the Fintech solution testing serve as a foundation for competent agencies to investigate, construct, and refine the legal framework and associated regulations as needed. 

3. Principles for judging organisations participating in the fintech regulatory sandbox

The evaluation of organisations involved in the experiment is conducted based on the following fundamental principles: 

1. The evaluation procedure guarantees transparency in the criteria, conditions, assessment, and selection processes; 

1. Involvement in the experiment does not imply that participating organisations will fulfil the legal business and investment conditions when laws have regulation; 

1. Credit institutions, foreign bank branches, and Fintech businesses that do not demand on engage in the experiment or have not been judged for participation must adhere to existing laws governing enterprises, investments, and other relevant regulations. 

4. Duration and scope of fintech regulatory sandbox

* Duration of experiment 

• The maximum experiment for Fintech solutions is 02 years, depending on each solution and field, from the time the State Bank issues the Certificate of Participation in the Testing Mechanism. The testing period may be extended according to regulations. 

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

* Scope of experiment/operation 

• Participating organisations are permitted to offer Fintech solutions solely within the parameters delineated in the Certificate of Participation in the Testing Mechanism. 

• The State Bank will determine the testing scope of the Fintech solution in the Certificate of Participation in the Testing Mechanism, based on the organization’s registration dossier, the specific proposal, and the opinions of the ministries. 

• Peer-to-peer lending organisations are permitted to offer peer-to-peer lending solutions solely within the scope defined in the Certificate of Participation in the Testing Mechanism. Such organisations are prohibited from engaging in any business activities beyond those stated in the Certificate; are forbidden from offering security interests for client loans; and are not operated as customers and providing peer-to-peer lending solutions to pawnshops. 

Note: The Decree becomes effective on July, 1st 2025.