Vietnam's lending sandbox: 13 of 16 P2P applications still under review

Implications for lenders

Companies planning P2P lending or third-party credit scoring in Vietnam should not plan on early sandbox approval: 13 of 16 P2P applications are still under review, and the credit-scoring and Open API applications were returned. The likely quicker route to launch is lending through or with a licensed bank or finance company, using biometric identity matching and the credit-information connection for onboarding and underwriting. Consent records and data-governance documents for credit-data sharing are worth preparing now, because they are likely to be needed both inside a licence and in a later sandbox application.

Implications

Facts

Sandbox: at the 2026 Financial and Banking Innovation Forum in Hanoi on 4 October, the banking regulatory sandbox under Decree 94/2025/ND-CP (in force since 1 July 2025) was described as having modest results. For peer-to-peer lending, 13 ¹ of 16 ² valid applications are under review. For credit scoring and Open API data sharing, 2 ³ applications were received, processed and returned (Banking Times; VietnamPlus).

Funding gap: State Bank of Vietnam (SBV) Deputy Governor Pham Tien Dung said financing for innovation "remained inadequate", as firms with intangible assets and unstable cash flows struggle to meet traditional credit requirements (VietnamPlus).

Payments and identity: in January–August 2026, cashless transactions rose 34.56% ⁴ in volume and 13.26% ⁵ in value year on year. By 25 September, over 174.5 million ⁶ individual customer records had been biometrically matched, and by 21 September the SBV's SIMO fraud-monitoring system had issued over 5.4 million ⁷ customer alerts (Banking Times). A credit-information connection system has operated since March 2026.

Analysis

The contrast is between infrastructure and licensing. Vietnam's payment and identity rails are scaling fast, and the SBV has added consent rules for credit-data sharing and a data-sharing agreement between the tax authority and the credit bureau CIC in recent weeks. The sandbox that would let non-bank models use that data for lending is moving slowly: the forum figures show P2P applications mostly still in review and no live credit-scoring or Open API pilots.

Thailand is taking a different route on new consumer-credit models, with the Bank of Thailand planning to license buy-now-pay-later providers from Q4 2026 under a dedicated rule. Vietnam's approach tests each P2P model case by case for a limited period, which gives the regulator more control but delays scale. For banks, the gap means the data-driven SME and consumer lending the SBV leadership has urged will, for now, run mainly through licensed banks and finance companies rather than new platforms.

Counterpoints and uncertainties

Review status can change quickly: approvals of several P2P applicants in the coming months would turn the picture from slow to active. The forum figures do not say why the credit-scoring and Open API applications were returned or whether they will be resubmitted. Faster cashless growth does not by itself mean more credit-relevant data, since value growth of 13.26% trails volume growth.