In short: to provide payment or e-money services in the UK, a Vietnamese fintech must be authorised by the Financial Conduct Authority (FCA) — as an authorised electronic money institution (AEMI) or an authorised payment institution (API). There is no “sandbox for outsiders”: carrying on regulated activities without permission is a criminal offence in the UK. In the other direction, Vietnam’s banking sandbox under Decree 94/2025/ND-CP (running since 1 July 2025) excludes foreign-invested enterprises from peer-to-peer lending trials. The two systems open up on different logics — fintechs must pick the right route from the start.
FCA licensing: two main doors for payment fintechs
Door one is the electronic money institution (EMI): issuing e-money and providing payment services. Conditions include adequate initial capital, robust governance and internal controls, fit-and-proper managers with suitable knowledge and experience, safeguarding of client funds (with the new CASS 15 rules applying from 7 May 2026), and compliance with the money laundering regulations. Door two is the authorised payment institution (API) under the Payment Services Regulations 2017: initial capital from EUR 20,000 (money remittance only) to EUR 125,000 (account and transaction execution services), application fees of GBP 2,820–5,640, and an FCA decision within 3 months for complete applications (12 months if incomplete). Realistic projects run 8–14 months from preparation.
Vietnam’s sandbox: Decree 94/2025 and the FDI exclusion
Decree 94/2025/ND-CP establishes a controlled testing mechanism for banking, open to three solutions: peer-to-peer lending, credit scoring and data sharing via Open API. The little-noticed key point: a company providing P2P lending solutions in the sandbox must NOT be a foreign-invested enterprise. A fintech with foreign capital — including a Vietnamese fintech that has taken foreign investment — cannot trial P2P domestically. Decree 382/2026/ND-CP (effective 6 October 2026) relaxes personnel conditions and simplifies applications, but does not touch this exclusion.
Choosing the route: three scenarios for Vietnamese fintechs
Scenario 1 — direct FCA authorisation: fits firms with a finished product, capital and a compliance team; realistic timeline 8–14 months with significant cost, but the licence covers the whole UK market. Scenario 2 — partnering as an agent of an authorised firm: the FCA lets EMIs/APIs operate through registered agents — a faster route to test the market before applying independently. Scenario 3 — staying in Vietnam’s sandbox: only viable for the other two solutions (credit scoring, Open API), or for P2P with a 100% domestic-owned company. Do not bring a “test first, licence later” mindset to the UK — the order there is reversed.
Standing compliance notes
Whichever route, two duties cannot be sidestepped: anti-money laundering (the MLRs in the UK; anti-money-laundering law in Vietnam) and client-money safeguarding (safeguarding/CASS in the UK). FCA applications most often fail on these two points — preparing them well from the start shortens the review considerably.
Frequently Asked Questions
- Does a Vietnamese fintech need FCA permission to serve UK customers?
- Yes, if the activity is regulated (issuing e-money, providing payment services). Operating without permission when required is a criminal offence in the UK — there is no “try first” mechanism for foreign firms.
- How long does FCA authorisation take?
- The FCA must decide within 3 months on a complete application (12 months if incomplete). In practice the whole project from preparation to authorisation usually takes 8–14 months.
- Is Vietnam’s banking sandbox open to FDI firms?
- Partly. Under Decree 94/2025, a P2P lending solution provider in the sandbox must not be a foreign-invested enterprise. The other two solutions (credit scoring, Open API) carry no such exclusion.
- Is there a faster way into the UK market than a standalone licence?
- Yes: operating as an agent of an FCA-authorised EMI/API that registers you. This is a common route to test the market before applying for an independent permission.
This article has been quality-reviewed by the FLAW AI Legal Council