Vietnam’s Banking Sandbox: How Decree 94 Opens a Smarter Path for Fintech Testing

Fintech founders often tell us the same thing: Vietnam is one of Southeast Asia’s most promising markets, but also one of the hardest to enter.

Until now, testing a new credit scoring model, open API solution, or lending app here usually meant investing heavily in licensing before proving product–market fit. For many innovators, that upfront commitment felt risky.

With Decree 94/2025/ND-CP, Vietnam is finally flipping that script.

The big news: A formal Banking Sandbox is now live

Starting July 1, 2025, Vietnam’s Banking Sandbox Framework officially goes into effect. For the first time, fintech companies can legally test specific financial services under the supervision of the State Bank of Vietnam — without needing a full license upfront.

Who’s eligible?

The sandbox covers only three areas for now:

✅ Credit scoring

✅ Open banking APIs

✅ Peer-to-peer (P2P) lending

Conditions?

– All sandbox testing must happen inside Vietnam.

– Foreign companies are welcome, if their testing operations remain local.

Why does this matter for fintech operators?

This isn’t just a policy update – it’s a shift in how Vietnam wants innovation to happen.

✅ De-risk product pilots: Early-stage companies can test new ideas in a regulated zone, without locking in high licensing costs too soon.

✅ Engage the State Bank early: Instead of hoping a product fits the rules later, teams can get real feedback during the sandbox phase.

✅ Prepare for scale: Strong compliance processes built during sandbox tests = faster, smoother licensing down the road.

It’s not a shortcut. It’s a smarter, phased path to local growth.

Three practical lessons for companies planning to enter

1️⃣ Scope tight, not broad

Sandbox tests must have clear limits:

– What features will be tested

– How long they’ll run (usually 12–24 months)

– How you’ll protect customer data, handle risk, and measure outcomes

A vague plan won’t get approved – precision matters.

2️⃣ Localization is non-negotiable

Vietnam’s regulators expect testing to be truly local:

– Local KYC and AML flows

– Data storage within Vietnam when required

– Local partners for distribution or onboarding

Foreign fintechs need to plan for this upfront, or risk delays.

3️⃣ Use the sandbox window wisely

The sandbox isn’t indefinite. It’s designed to test real usage, generate proof points, and build trust – not to run forever.

Smart teams use this window to:

– Build partnerships with local banks

– Adjust UX to local customer behavior

– Gather live user data for licensing or fundraising

The teams that succeed treat sandbox pilots as launchpads, not loopholes.

How this connects to Vietnam’s payment readiness

Vietnam’s inbound tourism and domestic digital payments are booming — yet cross-border payment flows are still patchy.

The Vietnam Tourism 2025 data shows:

– QR payment volume up 1,062% YoY

– Tourists still hit friction with “cash-only” businesses and SIM-locked e-wallets.

The sandbox helps close this gap by letting innovators safely test more interoperable payment experiences, lending models, and embedded APIs before going full-scale.

AppotaPay’s perspective

At AppotaPay, we see Decree 94 as more than a legal box to tick — it’s a chance for international fintechs to test smarter, localize faster, and build real regulatory trust.

Our role?

– Helping fintechs prep sandbox submissions

– Localizing onboarding & compliance flows

– Integrating cross-border payment rails

– Advising on what really works for Vietnamese users

“The sandbox doesn’t guarantee market success — but it removes a lot of the guesswork.”

What to do next

If you’re considering sandbox participation:

1️⃣ Read Decree 94/2025 carefully.

2️⃣ Confirm your product falls under credit scoring, open APIs, or P2P lending.

3️⃣ Get local partners early – or plan your legal structure to keep testing truly within Vietnam.

📩 Want help navigating? Contact our local team: biz@appotapay.com