Decree 94/2025/ND-CP created a controlled testing mechanism for the banking sector covering three solution groups: credit scoring, data sharing through open application programming interfaces, and peer-to-peer lending. For peer-to-peer lending this is the first clear trial corridor in Vietnam, replacing the grey zone in which such platforms operated for years. This article examines the permitted trial scope, the layers of protection owed to lenders and borrowers, the conditions a platform must satisfy, and what happens to outstanding loans when the trial ends without a formal licence.
Three solution groups in the sandbox and the trial boundary for P2P
Testing under Decree 94/2025/ND-CP is not a miniature banking licence. A participant may deploy only the solution approved by the State Bank of Vietnam, within the customer scope, transaction limits and duration recorded in the approval decision for its own file. The trial lasts no more than two years from the date the participation certificate is issued, and throughout that period the participant reports periodically, remains under supervision and can be ordered to stop if risks exceed control. For credit scoring, the trial focuses on data models and creditworthiness algorithms used in lending decisions, with requirements on lawful data sources and the ability to explain scoring outcomes to affected customers.
For peer-to-peer lending the permitted scope must be read narrowly: the platform connects parties and supplies information infrastructure between lenders and borrowers, and must not morph into an entity that raises funds and lends on its own book like an unlicensed bank. A fintech applicant has to evidence technology capability, credit risk governance, customer identification procedures and a user-protection plan. A common misconception is that a strong product automatically earns sandbox entry; in practice each approval is file-specific, and the scope ultimately granted can be considerably narrower than the scope the applicant originally proposed in its submission dossier.
Layers of user protection and operating conditions for P2P platforms
The first protection layer is risk transparency: the participant must disclose the experimental nature of the service, the lender’s risk of losing principal, and the fact that a peer-to-peer loan is not an insured deposit. The second layer is a complaint mechanism with a named receiving point, response deadlines and an escalation path when disputes arise. The third layer is structural: user funds must be segregated from the platform’s own assets and routed through accounts at a cooperating credit institution, so that money not yet disbursed does not fall into the platform’s liquidation estate if the platform itself runs into financial difficulty.
On operating conditions, a sandbox peer-to-peer platform must show financial and governance capacity proportionate to its approved trial scale, information systems meeting security requirements, borrower assessment procedures built on verifiable data, and contingency arrangements if default rates breach registered thresholds. The management team needs a dedicated compliance owner, because supervisory reports to the State Bank of Vietnam are not accepted on estimated figures. Applicants should also build debt-collection and user-support procedures into the trial dossier itself, rather than waiting for the first overdue loan to appear before designing how arrears will be chased and how affected lenders will be kept informed.
Frequently Asked Questions
What scope are credit scoring and P2P lending allowed to be trialled within the sandbox?
Trial scope is fixed file by file: the participant may run credit scoring or peer-to-peer lending only within the customer limits, transaction caps and duration that the State Bank of Vietnam sets in its approval decision, for no more than two years from issuance of the participation certificate. This is not a market-wide business licence; stepping outside the approved scope, for example by onboarding a customer segment that was never approved, breaches the trial conditions and can lead to suspension of the trial. Every product feature should be checked against the approval wording before it is released to users.
By what mechanisms are users taking part in P2P lending inside the sandbox protected?
Users are protected by several reinforcing layers: the platform must disclose risks prominently before users commit funds, including the risk that borrowers fail to repay and the experimental status of the model; it must operate a complaint channel with an accountable owner; and user money must be segregated through accounts at a cooperating credit institution instead of sitting in the platform’s operating accounts. Even so, lenders should understand that a peer-to-peer loan is not a bank deposit and carries no deposit insurance, so diversifying across many small loans remains the most important self-protection available to an individual lender.
What conditions on capital, risk governance and segregation of money flows must a P2P platform satisfy?
The conditions rest on three pillars: finance and governance, technology, and money flows. The platform must evidence financial capacity matching its trial scale, a risk governance structure with a compliance owner, customer identification, and credit assessment based on verifiable data. Its systems must meet information security requirements and keep transaction trails available for supervision. On money flows, lender and borrower funds must pass through segregated accounts at a cooperating credit institution; the platform may not use those flows for its own business. This segregation duty is the condition supervisors watch most closely once a trial is actually running.
When the trial period ends and the P2P model has not yet received a formal licence, how are outstanding loans handled?
If the trial expires and the model has not received a formal licence, the participant may not sign new loans and must implement a wind-down plan for outstanding loans as decided by the State Bank of Vietnam. The usual approach is to keep collecting debts until settlement under that approval, while handing over data and supporting users if a licensed entity takes over servicing. The worst outcome is a platform quietly shutting down and leaving lenders without a collection counterparty; loan documents and the trial file should therefore name the party responsible for post-trial debt collection from the very beginning.
Enter the P2P sandbox with FLAT Law Firm: file review before you approach the State Bank
FLAT Law Firm helps fintech companies build participation files under Decree 94/2025/ND-CP: matching product features to the approvable trial scope, drafting risk-disclosure and complaint materials for users, structuring segregated money flows through a cooperating credit institution, and above all preparing the wind-down plan for outstanding loans at the end of the trial. Contact FLAT Law Firm at the model-sketching stage, because repairing a defective money-flow structure after a trial has launched costs far more than designing it correctly in the very first dossier.
