Decree 94/2025/ND-CP (“Decree 94”) has opened Vietnam’s first legislation for a fintech sandbox since 1 July 2025, however, 18 months on without much progress. By far, there has yet to be any name permitted under the current sandbox framework, or maybe no official name announced?
On 6 October 2026, the Government amended it through Decree No. 382/2026/ND-CP (“Decree 382”), effective the same day.
The amendment is about getting into the box, not making the box bigger. Will this update be impactful? We are not so sure.
• No more board or shareholder resolutions approving the fintech scheme.
• The State Bank must pull business registration, degree and criminal record data from national databases before asking applicants for paper.
• The fit-and-proper test for the fintech’s legal representative or CEO loosens from “degree and 2 years of finance or banking management” to “a broader degree list or relevant management experience”. Payment intermediaries and IT now count as relevant experience.
• The scheme no longer has to show “full satisfaction” of every Article 8 criterion upfront. It focuses on a demo, target customers and information-system security level.
• Shorter appraisal clocks, 80 days for credit scoring and Open API and 90 days for P2P. It is much shorter than 90 working days set out under Decree 94.
• Shorter clocks for adjustments, extensions, early termination and completion certificates: 25 working days, down from 30 to 45.
• Digital signatures on forms, and wording aligned with the new cybersecurity law.
Decree 382 also lets the stopgap simplifications under Resolution 24/2026/NQ-CP lapse and writes them into the sandbox decree itself, which is the right home for them. The sandbox still covers only credit scoring, Open API and P2P lending. Testing is still two years, domestic only, and P2P is still closed to foreign-owned companies. Pricing, interest caps and debt collection for P2P are still unaddressed.
