Vietnam's Decree 382 eases application rules for its banking sandbox

Implications for lenders

Companies planning P2P lending or credit scoring in Vietnam face fewer paperwork hurdles, but with 13 of 16 P2P files still under review, approval timing remains uncertain. Applicants may need a simulation of the solution, a target-customer definition and security documentation ready at filing, which favours teams that already have underwriting and data-protection processes in place. Partnering with a licensed lender can remain the faster route to market while the review continues.

Implications

Facts

Decree: the Government issued Decree 382/2026/ND-CP, signed by Deputy Prime Minister Nguyen Van Thang and effective on 6 October, amending Decree 94/2025/ND-CP on the controlled testing mechanism (sandbox) in banking. Sources: Thi truong Tai chinh Tien te (8 October), Bao Dau tu (7 October).

Qualifications: a fintech's legal representative or CEO previously needed both a university degree in a listed field and management experience in finance or banking. Under the amendment, a degree or 2 years ¹ of experience is required, now an alternative to a relevant degree; previously required in addition to one. Degree fields now include accounting and auditing, and experience in payment intermediation or information technology also counts.

Application: board or shareholder resolutions approving the proposal are no longer required. Proposals must include a simulation model or demo, the target customer group and a technical description showing the information system meets the required security level. The State Bank of Vietnam (SBV) must use national and specialised databases for judicial records, degrees and business registration before asking for paper copies, and an executive's background statement must be dated within 6 months ² of filing. Applications may also be filed through a third party or an authorised representative.

Analysis

Over time, the sandbox has produced few approvals. At an SBV forum on 4 October, 13 ³ of 16 ⁴ valid peer-to-peer lending applications were still under review, and the credit-scoring and Open API applications had been returned. The amendments lower the cost of applying and widen the pool of eligible founders; they do not change the testing conditions themselves, so they are unlikely on their own to clear the review backlog.

Across the region, Vietnam is moving on entry while Thailand is moving on data: the Bank of Thailand is preparing an alternative-data exchange and free credit-bureau checks, whereas Vietnam's sandbox still requires P2P participants to connect to the national credit information centre. For credit-scoring firms, the decisive question in Vietnam remains how consent and data-sharing rules apply inside the sandbox.

Counterpoints and uncertainties

The decree changes application rules, not the testing limits or the SBV's review capacity, so approvals may not accelerate. Detailed security criteria are set in an appendix whose application in practice is not yet known. Foreign-invested firms remain outside the fintech category, which limits the pool of applicants.