Vietnam is moving quickly to position itself as a regional hub for digital innovation. Recently, Vietnam has been actively developing and implementing “controlled testing mechanisms”, also known as regulatory sandboxes. A sandbox lets businesses test emerging technologies, products or business models within a defined scope and timeframe, under regulatory oversight. The aim is to foster innovation while ensuring risk control and protecting the participants’ legitimate rights and interests.
For financial services, fintech players, and investors, sandboxes provide both a structured way to experiment and signal where Vietnam’s policy environment is heading.
Current framework
The current legal framework for sandboxes in Vietnam consists of the following key regulations:
- Decree No. 94/2025/ND-CP, issued on April 29, 2025, and effective as of July 1, 2025, which provides a regulatory sandbox for fintech solutions in the banking sector.
- The Law on Digital Technology Industry (DTI Law), passed on June 14, 2025, and effective as of January 1, 2026. The DTI Law acknowledges regulatory sandboxes as a state policy to accelerate innovation and digital transformation in Vietnam.
- The Law on Science, Technology and Innovation (STI Law), passed on June 27, 2025, and effective as of October 1, 2025. The STI Law introduces a definition of “regulatory sandbox”. It devotes a separate section on the major principles and features of sandboxes, liability waivers and measures for the protection of the participants’ legitimate rights and interests.
- Resolution No. 222/2025/QH15 on International Financial Centers (IFC), and Draft Decree on IFC, both effective as of September 1, 2025, providing a policy and regulatory framework for fintech sandboxes in IFCs to be established in Ho Chi Minh City and Da Nang.
- Resolution No. 5/2025/ND-CP on piloting crypto asset market in Vietnam. It was issued on September 9, 2025 and will be effective for 5 years. The resolution creates a sandbox for crypto asset service providers and sets requirements for technical conditions, operations, financial capacity and expertise criteria.
Main features of Vietnam’s sandbox framework
- General principles and requirements: A sandbox must follow the principles of transparency, equality, responsibility, security, safety and public interest. Sandboxes apply to digital products and services, including hardware, software, digital content. Participants receive exemptions from civil, administrative and penal liabilities provided that they fully comply with the law and act for the common good. These also include involved government bodies and licensed entities. These entities must take measures to protect the legitimate rights and interests of the concerned stakeholders. This includes warning and regularly assessing risks, providing accurate information, having mechanisms to ensure data privacy and security, addressing relevant requests and complaints, and paying damages when required. There is an exception in cases where they’re exempt from such liability. Sandbox periods last up to three years, with a possible one-time extension of another three years. Participation does not automatically qualify a company under future licensing or investment conditions.
- Fintech sandbox in banking sector: Three categories of fintech solutions are eligible for the sandbox mechanism in the banking sector. These include credit scoring, data sharing via open application programming interfaces (APIs), and peer-to-peer (P2P) lending solutions. Eligible entities cover credit institutions, foreign bank branches and fintech companies legally established in Vietnam. Those that wish to participate in the sandbox have to submit an application to the State Bank of Vietnam (SBV) for review and approval. They must acquire a Certificate of Participation from the SBV. Credit institutions cannot engage in P2P lending solutions is important note. Their testing is restricted within the territory of Vietnam, i.e. cross-border testing is prohibited. Each solution’s maximum testing period is two years and the SBV may allow up to two one-year extensions.
- Sandbox in IFC: Sandbox participants, including licensed entities, are allowed not to apply certain technical regulations and standards. Sandbox participants may skip business conditions and licensing procedures that do not fit the new technologies, products, or business models they are testing. They can also enjoy exemption from liability for damage to the state in force majeure circumstances, provided that they have fully adhered to the testing procedures. Local budgets may provide fintech enterprises with non-refundable funding support for sandbox projects in fintech and innovation. Ho Chi Minh City is expected to be the hub of fintech sandboxes.
- Sandbox for digital assets: According to the newly-issued regulations, any entity that wants to operate a crypto asset exchange must be a Vietnamese limited liability or joint stock company with a minimum charter capital of VND10 trillion. Crypto assets are only offered and issued to foreign investors and may only be traded between foreign investors through crypto asset service providers licensed by the Ministry of Finance. The sandbox participants are subject to stringent requirements, particularly on information technology infrastructure and the highest cybersecurity standards.
Why it matters
Vietnam has been recognized as one of the fastest movers in innovation globally and also one of the best performers in the Association of Southeast Asian Nations (ASEAN). By adopting regulatory sandboxes, the country aims to further accelerate innovation and digital transformation. Its approach to the sandbox framework aligns with international and regional trend. It is based on the study of other countries’ experiences, especially the United Kingdom and Singapore. Similar to these models, Vietnam’s sandbox mechanism focuses on a specific sector, i.e. fintech. The mechanism aims to balance innovation with consumer protection. However, it may differ from the others in eligibility criteria, testing duration and regulatory exemptions for participants.
Sandboxes will offer companies in Vietnam, especially start-ups, a safe and flexible environment to test new technologies, such as AI or blockchain, and to access new funding sources. They will also offer investors a way to evaluate risks and identify potential projects for investment.
As Vietnam’s regulatory environment is evolving. It’s important for businesses to closely monitor regulatory developments and work with the government, particularly the Ministry of Finance and the State Bank of Vietnam. Such engagement helps shape an enabling environment for the digital economy in general and fintech in particular.
Sources:
- https://datafiles.chinhphu.vn/cpp/files/vbpq/2025/5/94-ndcp.signed.pdf
- https://datafiles.chinhphu.vn/cpp/files/vbpq/2025/7/71qh15.signed.pdf
- https://datafiles.chinhphu.vn/cpp/files/vbpq/2025/7/93qh.signed.pdf
- https://datafiles.chinhphu.vn/cpp/files/vbpq/2025/7/222qh.signed.pdf
- https://datafiles.chinhphu.vn/cpp/files/duthaovbpl/2025/Thang8/dtnd-tttc.pdf
- https://xaydungchinhsach.chinhphu.vn/toan-van-nghi-quyet-so-5-2025-nq-cp-ve-trien-khai-thi-diem-thi-truong-tai-san-ma-hoa-tai-viet-nam-119250909184045221.htm
- https://asean.org/global-innovation-index-2024-asean-continuing-to-cement-itself-as-a-global-innovation-hub/
