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Decree No. 94/2025/ND-CP is the first legal instrument in Vietnam to establish a regulatory sandbox framework for fintech models in the banking and financial sector.
Unlike previous regulations, which were largely fragmented and reactive, Decree No. 94/2025/ND-CP lays a solid foundation for:
The official development of Vietnam’s fintech ecosystem
Attracting investment into financial technology
Managing systemic risks, protecting users, and ensuring monetary and financial safety
???? In short, from 2025 onward, fintech in Vietnam officially enters the “major league” of regulated markets.
For many years, fintech in Vietnam developed rapidly but outpaced the legal framework:
E-wallets and peer-to-peer lending (P2P Lending) operated in legal “grey zones”
Investors lacked a clear regulatory basis to assess risk
Regulators faced difficulties intervening when incidents occurred
Decree No. 94/2025/ND-CP was introduced to:
Test innovative models without compromising the safety of the financial system
Create a legal runway for innovation
Filter out unsustainable or distorted fintech models, while supporting viable ones
Under Decree No. 94/2025/ND-CP, the sandbox applies to several key fintech sectors, including:
E-wallets
Digital payment solutions
New payment technologies (QR payments, tokenization, embedded finance, etc.)
???? Regulatory focus: fund safety, anti-money laundering (AML), and user protection.
This is the most closely watched sector.
The Decree clearly stipulates that:
P2P lending platforms are not credit institutions
They must not engage in illegal capital mobilization
They are prohibited from committing guaranteed returns like banks
???? Objective: to prevent P2P lending from degenerating into technology-driven loan sharking.
Remote customer identification
Application of AI and Big Data in credit assessment
Data connectivity with banks and financial institutions
???? Core issue: personal data protection and information security.
Decree No. 94/2025/ND-CP remains open to additional fintech models such as:
Insurtech
Regtech
Wealthtech
Open Banking
Provided that they can demonstrate innovative value and effective risk control mechanisms.
Not every startup qualifies.
Fintech enterprises must:
Have clear legal entity status in Vietnam
Offer a technologically feasible solution at the testing stage
Present risk management and incident response plans
Meet minimum financial capacity requirements
???? The sandbox is not a permanent license, but a rigorous testing phase.
To pilot new fintech products and services
To access the market within controlled limits
To transition to official licensing if all requirements are met
Periodic reporting to regulatory authorities
Strict compliance with sandbox limitations
Protection of user rights and interests
Suspension or termination of testing upon regulatory request
For investors, the Decree sends a positive and reassuring signal:
Reduced legal risk when investing in fintech
A clearer basis to distinguish compliant models from high-risk ones
Increased exit opportunities through M&A or IPOs due to regulatory clarity
???? Fintech with a sandbox framework = fintech that is more investable.
Fintech enterprises operating outside the sandbox or violating its conditions may face:
Suspension of operations
Significant administrative penalties
Mandatory refunds to customers
Criminal liability in serious cases
This is no longer merely a technology issue.
Fintech companies must:
Standardize their legal structure from the outset
Design products based on a “legal by design” approach
Assess risks related to data, finance, and users
Engage early with specialized fintech legal advisors
In the context of Decree No. 94/2025/ND-CP:
Lawyers are no longer just “document drafters”
They are strategic partners enabling fintech firms to survive, scale, and raise capital
Early and proper legal advice helps to:
Shorten the time required to enter the sandbox
Avoid fatal legal mistakes
Increase enterprise value in the eyes of investors
Decree No. 94/2025/ND-CP does not restrain fintech—it filters fintech.
Serious and compliant enterprises will have the opportunity to break through.
Ambiguous or opportunistic models will be eliminated from the market.
2025 marks the beginning of a selective phase for Vietnam’s fintech sector—where legal compliance becomes the key to survival.
