New developments in fintech and P2P lending regulatory sandbox

Decree No. 94/2025/NĐ-CP, issued by the Government on April 29, 2025, outlines the controlled trial mechanism in the banking sector for the deployment of new products, services, and business models based on technological solutions.

The fintech solutions eligible for participation in the sandbox include credit scoring, data sharing via open API, and peer-to-peer (P2P) lending. These technologies, when implemented effectively, are expected to lay a foundation for enhancing banking services and advancing digital banking—aligned with the goals of the Politburo’s Resolution No. 57-NQ/TW on breakthroughs in science, technology, innovation, and national digital transformation.

Since the effective date of the decree on July 1, 2025, the SBV has actively implemented specific programs and actions, ranging from policy communication to the development of detailed administrative procedures to operationalize the sandbox framework.

The newly issued administrative procedure set provides comprehensive guidance on receiving and processing registration dossiers, the timeline, implementation steps, and result delivery.

From a policy management and implementation perspective, this represents an impressive timeline. In a short period, the SBV officially released and published the procedural documentation on the National Public Service Portal and the SBV’s own portal for public access.

The new administrative procedure set includes six procedures under Decree 94’s sandbox mechanism, namely:

1. Registration for participation in the sandbox for credit scoring and open API data-sharing solutions;

2. Registration for participation in the sandbox for peer-to-peer lending;

3. Requests to adjust sandbox solutions;

4. Requests to terminate and revoke sandbox participation certificates;

5. Requests to extend the sandbox testing period;

6. Certification upon completion of the sandbox period.

P2P lending activities are officially being piloted under a controlled sandbox framework for a period of two years. These procedures are carried out by the SBV through its designated departments: the Monetary Policy Department oversees those related to P2P lending, while the Payment Department handles those involving credit scoring and open API data-sharing.

Each procedure is detailed with clear instructions regarding steps, methods of implementation, documentation requirements, dossier quantity, processing time, eligible participants, responsible agencies, and expected outcomes (issuance or denial of certification). The procedures also include form templates, conditions for eligibility, and the legal basis—note that these are public administrative procedures with no fees.

The new administrative procedures aim to facilitate the sandbox testing of fintech solutions such as peer-to-peer lending, credit scoring, and open API-based data sharing. Therefore, effective communication, guidance, and consulting are necessary to help applicants prepare their documentation and fulfill procedural requirements.

Special emphasis is placed on planning and fulfilling prerequisites to ensure ease in administrative implementation and, most importantly, successful sandbox participation. This is crucial in fostering new banking services and business models that align with the ongoing digital transformation and the Fourth Industrial Revolution.

According to SBV Deputy Governor Phạm Tiến Dũng, the three core solutions considered for the sandbox under Decree 94 are credit scoring, open API data sharing, and P2P lending. In addition, during the implementation of the decree, the SBV will continue reviewing and updating new banking products, services, and business models to evaluate and potentially expand the scope of the sandbox mechanism.

Speaking at a forum on the implementation of Decree 94, the Deputy Governor noted that the decree’s deployment would serve as a driving force for digital transformation in the financial and banking sectors. It aims to build on previous successes and contribute to the broader economic development.

Mr. Ron H. Slagen, Deputy Country Director of the Asian Development Bank (ADB) in Vietnam, remarked that Vietnam’s financial system is undergoing significant transformation, driven by technologies such as cloud computing, big data analytics, open APIs, blockchain, and AI. These changes are reshaping traditional banking and driving the rise of fintech companies.

The newly issued Decree 94 on the fintech sandbox marks a pivotal step in establishing a legal framework that allows fintech companies to test new products and services under the close supervision of the SBV. The synergy between the fintech pilot mechanism and P2P lending is expected to encourage continued innovation and expansion in Vietnam’s digital financial service landscape.