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In brief

With the rise of new technology and digital transformation in recent years, Vietnam’s government has been working on a regulatory framework to govern financial technology (fintech) activities in the country. Back in 2020, the first ever draft of a regulatory sandbox was released, with the expectation that Vietnam would soon have a regulatory framework for fintech to keep up with this global trend. However, there has been no development in the launch of the sandbox until early this March 2024.

On 4 March 2024, the State Bank of Vietnam (SBV) released a new draft decree (“Draft Decree“) on the regulatory sandbox for the banking sector in Vietnam. The Draft Decree proposes a comprehensive framework for a regulatory sandbox program applicable to fintech solutions (“Regulatory Sandbox“) by detailing, among others, eligible solutions, eligibility criteria for service providers, and requirements for participation.

Key takeaways

The Draft Decree introduces various changes and new proposals compared to the previous versions, with the following highlights:

  • To participate in the Regulatory Sandbox, an entity must be (i) a credit institution under the Law on Credit Institutions,1 or (ii) an independent fintech company or fintech solution provider (“Fintech Companies“) established and operating in Vietnam and partnering with credit institutions or foreign banks’ branches (“Eligible Entity(ies)“). The deployment of all fintech solutions covered by the Regulatory Sandbox (“Solutions“) is limited to the territory of Vietnam, and cross-border supply from Vietnam to offshore is prohibited.
  • The Solutions are currently limited to only three groups of Solutions — namely credit scoring, open API and peer-to-peer (P2P) lending — compared to the previous versions.
  • Under the Draft Decree, Eligible Entities must obtain a certificate for registration of participation in the Regulatory Sandbox (“Registration Certificate“) to be issued by the SBV.
  • Along with the general criteria that apply to all Eligible Entities, Fintech Companies must satisfy several additional conditions to participate in the Regulatory Sandbox, depending on the Solutions that the Fintech Companies provide.
  • Eligible Entities in the Regulatory Sandbox are subject to an obligation to report to the SBV on a periodic and ad hoc basis, which includes reporting on operational criteria for the Solutions, emerging risks and results of the launch of the Solutions.
  • The Regulatory Sandbox will have a maximum term of two years from the issuance date of the Registration Certificate, depending on the Solutions.
  • The Regulatory Sandbox can be extended up to two times, and each extension period should not exceed one year.
  • Upon the completion of the Regulatory Sandbox, a completion certificate (“Completion Certificate“) will be granted to the Eligible Entity if: (i) the official legal framework for the Solution has been finalized and comes into effect; or (ii) the implementation of the Solution does not violate current regulations.

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Oanh Nguyen is a partner in Baker McKenzie Vietnam and has been practising capital markets, banking and finance, M&A, and commercial law for more than 25 years. Knowledgeable about all aspects of investments, she advises on all types of transactions, ranging from investment structures to project structures and their related financing. She has focused on public M&A matters, including major IPOs and projects finance.

Oanh is a respected presenter in the areas of finance and capital markets. In addition, she has lectured at the Ho Chi Minh City Bar Association. She also serves as a legal advisor to the Capital Market Committee of Ho Chi Minh City American Chamber of Commerce.


Thuy Van Pham is a special counsel at the Firm's Ho Chi Minh City office with more than 10 years of experience advising on investment, banking and finance in Vietnam. She has been involved in many transactions, including cross-border financing deals and M&A transactions in Vietnam across a wide range of industries, including banking and finance, insurance and securities, manufacturing, oil and gas, real estate, telecommunications. Van has also been advising major banks in Vietnam on regulatory issues for their daily operations.


Viet Trung Nguyen is an Associate in Baker McKenzie, Hanoi office.

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