Context: P2P lending in Vietnam once grew ‘outside the law’, with a series of platforms collapsing over usury and fund misappropriation; the 2025 sandbox mechanism is the first time this model has an official path — but a narrow and conditional one.
The Legal Framework That Decides the Issue
Before Decree 94/2025/ND-CP, Vietnam had no licence for peer-to-peer lending: platforms calling themselves ‘pure technology connectors’ while actually raising lenders’ money and promising interest were repeatedly warned by the State Bank and the Ministry of Public Security as disguised activities, with several cases criminally handled where misappropriation or usury was involved. From 1 July 2025, Decree 94/2025/ND-CP brings P2P lending into the controlled-testing mechanism in banking, alongside credit scoring and Open API, with testing of at most 2 years and conditions on customer scope, limits and supervision reporting set by the State Bank for each approved case.
Inside or outside the sandbox, the loan between lender and borrower remains a civil relation under the interest cap of the Civil Code 91/2015/QH13: agreed interest may not exceed 20% per year, and the excess is not protected by law. What investors in a P2P platform must understand is that lenders’ money is not a deposit, carries no deposit insurance, and a testing platform may not promise capital preservation. If the platform fails or the borrower cannot pay, the lender claims under the civil loan relation with the borrower personally — the platform is liable only within its own fault, such as providing false information or breaching operating commitments.
Beyond the Text: How Authorities and the Market Actually Operate
The signs separating a P2P platform on the sandbox path from a disguised scheme lie in three questions: is there a State Bank testing approval, does lenders’ money pass through bank accounts instead of the platform’s internal wallet, and do the marketing materials promise fixed interest or capital preservation? One wrong answer, and an investor should treat it as a model outside the law.
What to Do: Action Checklist
The steps below turn the analysis above into concrete work:
- First, test your own situation against this ground: Before Decree 94/2025/ND-CP, Vietnam had no licence for peer-to-peer lending: platforms calling themselves ‘pure technology connectors’ while actually raising lenders’ money and promising interest were repeatedly warned by the State Bank and the Ministry of Public Security as disguised activities, with several cases criminally handled where misappropriation or usury was involved.
- Record the application point specific to this case instead of copying conclusions from another case: Inside or outside the sandbox, the loan between lender and borrower remains a civil relation under the interest cap of the Civil Code 91/2015/QH13: agreed interest may not exceed 20% per year, and the excess is not protected by law.
- Prepare the evidence and file relating to the following point before dealing with authorities or partners: The signs separating a P2P platform on the sandbox path from a disguised scheme lie in three questions: is there a State Bank testing approval, does lenders’ money pass through bank accounts instead of the platform’s internal wallet, and do the marketing materials promise fixed interest or capital preservation? One wrong answer, and an investor should treat it as a model outside the law.
- Answer the question clients ask most directly with this conclusion, and keep it on file: Lawful only through the controlled-testing path of Decree 94/2025/ND-CP with State Bank approval, for at most 2 years of testing. Outside the sandbox, Vietnam has no standing P2P lending licence; a self-operating platform outside this mechanism faces warnings and handling as a disguised activity.
Frequently Asked Questions
Is opening a P2P lending platform in Vietnam lawful?
Lawful only through the controlled-testing path of Decree 94/2025/ND-CP with State Bank approval, for at most 2 years of testing. Outside the sandbox, Vietnam has no standing P2P lending licence; a self-operating platform outside this mechanism faces warnings and handling as a disguised activity.
What is the maximum P2P lending interest rate?
A P2P loan remains a civil loan, so the 20% per year cap of the 2015 Civil Code applies; interest above the cap is unprotected. Advertised rates far above this level signal promises paid by off-law mechanics, usually tied to capital-loss risk.
If a P2P platform collapses, how do investors recover money?
Lenders claim from the borrowers themselves under the civil loan contract, because P2P money is not a deposit and carries no insurance. If there are signs of misappropriation or fraud by the platform operator, the additional path is reporting to investigators with the bank money-flow file.
This article has been quality-reviewed by the FLAW AI Legal Council