On April 29, 2025, the Vietnamese Government issued Decree No. 94/2025/NĐ-CP on a controlled testing mechanism in the banking sector.
This is the first decree in Vietnam to establish a legal framework for piloting innovative financial products, models, and technology-driven services – marking an important milestone in institutionalizing financial innovation in the country.
In the accelerating digital economy, innovation is no longer a slogan but a matter of survival. However, emerging technologies and business models – from fintech and AI to blockchain – still face regulatory bottlenecks. That is why the sandbox model, or “controlled experimentation,” has become a crucial catalyst for Vietnam’s next leap forward.
When policy dares to “experiment”
A sandbox acts as a policy laboratory – a safe space where new ideas can operate within defined boundaries, timeframes, and oversight.
Instead of waiting for perfect regulations, sandboxes allow businesses and regulators to co-learn, co-develop, and refine frameworks in real time – ensuring safety while encouraging innovation.
This model is not new. Countries like the UK, Singapore, Thailand, and Australia adopted sandbox frameworks nearly a decade ago, particularly in fintech. Singapore’s Monetary Authority (MAS) is a leading example: through sandbox experiments, the country successfully tested e-wallets, digital banking, and blockchain solutions before rolling out official regulations – helping Singapore emerge as Asia’s fintech hub.
Vietnam’s first steps
In Vietnam, the concept of a sandbox has gradually made its way into policymaking.
The State Bank of Vietnam (SBV) first introduced a sandbox draft for fintech, enabling trials in peer-to-peer lending, digital payments, and electronic identification (eKYC). Building on that, on June 17, 2025, the Government officially issued Decree No. 94/2025/NĐ-CP – establishing a controlled testing framework for the banking sector.
The core objective of the decree is to create a safe environment for fintech experimentation while using real-world outcomes to inform and improve financial regulations.
Four key goals of the sandbox
The decree focuses on four main objectives:
- Define clear principles, procedures, and approval criteria for fintech testing.
- Use data and outcomes from trials to refine and modernize the legal framework.
- Encourage innovation in financial products, services, and business models.
- Promote financial inclusion and ensure consumer protection.
Three fintech areas open for testing
Decree 94 allows sandbox implementation in three major fintech areas:
- Credit Scoring – leveraging non-traditional data sources to assess creditworthiness.
- Open API Data Sharing – enabling cross-platform integration among financial institutions.
- Peer-to-Peer (P2P) Lending – connecting borrowers and lenders using the Vietnamese dong within a regulated scope.
These are among the most dynamic fields shaping digital finance, and sandbox trials provide a structured path to validate innovations before large-scale deployment.
Eligibility and testing period
To join the sandbox, financial institutions or fintech firms must demonstrate solid financial capacity, technical capability, and proven innovation value. They are also required to develop clear risk management frameworks and consumer protection plans.
Each testing period lasts up to two years, with the possibility of two extensions, each not exceeding one year. The scope and scale of testing are defined in the participation certificate issued by the SBV.
Supervision and consumer protection
The SBV retains the authority to request regular reports, conduct inspections, and suspend testing in case of violations.
Participants must ensure data privacy, transparency in complaint handling, and the ability to integrate monitoring systems upon request.
Why sandbox matters for innovation
The introduction of Decree 94 goes beyond fintech. It lays the foundation for policy experimentation in other sectors — including insurance, education, healthcare, and energy.
A sandbox framework allows:
- Businesses to test innovative ideas safely without regulatory uncertainty.
- Regulators to collect real-world data and design more adaptive legal frameworks.
- The financial system to foster a culture of experimentation and innovation.
The sandbox mindset – foundation of an innovation nation
Above all, sandbox is not merely a legal tool — it represents a new way of thinking about development.
It means daring to experiment, but doing so strategically. It means accepting failure, but failing safely to learn and adapt faster.
That is the mindset shared by the world’s most innovative economies — from Silicon Valley to Tel Aviv.
If Vietnam can apply sandbox principles flexibly across sectors — from finance and education to healthcare and energy — innovation will no longer be a slogan, but a true engine of sustainable growth.
Fostering Controlled Innovation with IBP
A sandbox is more than just a legal framework – it represents a mindset of “daring to experiment within a safe zone,” where businesses can innovate, learn, and grow sustainably.
To help Vietnamese enterprises build practical innovation capabilities, IBP collaborates with experts to develop the Corporate & Leadership Innovation Solution Suite, empowering businesses to:
- Design and test innovation models in a controlled environment.
- Leverage data and technology to optimize operations and develop new products.
- Build a sustainable innovation mindset as the foundation for long-term growth.
