Foreign Investment

Vietnamese Fintech Expanding to the UK: FCA Licensing and the ‘Domestic-Only Sandbox’ Trap

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