Digital Banking and Fintech in Vietnam 2026: New Regulations

2026 is a pivotal year for Vietnam’s digital banking and fintech legal framework. The headline: Decree 382/2026/ND-CP just “opened the valve” on the regulatory sandbox — easing conditions, simplifying dossiers, and allowing reuse of existing digital data. This article maps the 4-pillar legal framework — payment intermediary licensing, sandbox, Open API/transaction security, foreign ownership limits — plus the state of pure digital banks and the latest market moves.

Timeliness note: Decree 382/2026 was issued around early October 2026 (about one week old at research time) — this article is current to 14 October 2026; specific article/clause numbers should be verified against the full text once officially published.

1. Pillar 1: Payment intermediary licensing

Under Decree 52/2024/ND-CP (effective 1 July 2024), payment intermediary activities (e-wallets, payment gateways, switching, clearing, etc.) require licensing by the State Bank of Vietnam (SBV). Minimum charter capital:

VND 50 billion: e-wallet and payment gateway services;
VND 300 billion: financial switching and electronic clearing services.

The decree also clarifies e-money (monetary value stored on electronic means, at par with the Vietnamese dong). The platform law is the Law on Credit Institutions 32/2024/QH15 (effective 1 July 2024), amended by Law 96/2025/QH15 (effective 15 October 2025).

2. Pillar 2: The regulatory sandbox — what’s new in Decree 382/2026

Decree 94/2025/ND-CP (29 April 2025, effective 1 July 2025) created the controlled-trial (sandbox) mechanism for banking with 3 solution groups: credit scoring, Open API, and peer-to-peer lending. Trial duration: up to 02 years per solution; the SBV issues a Certificate of sandbox participation.

What’s new in Decree 382/2026/ND-CP (amending Decree 94/2025, ~October 2026) — “opening the valve”:

Multi-channel filing (including online) — instead of paper only;
SBV reuses existing digital data — businesses do not re-submit documents the state already holds;
Eased personnel conditions: a specialized university degree or ≥ 02 years of experience (instead of both);
Removed the requirement for a Members’ Council/Board of Directors/GMS resolution on the sandbox proposal.

In addition, Circular 19/2026/TT-NHNN (10 June 2026) decentralizes certain sandbox procedures to regional SBV branches — shortening the dossier’s journey.

3. Pillar 3: Open API and electronic transaction security

Circular 64/2024/TT-NHNN (effective 1 March 2025) — the legal framework for Open API in banking: banks open application programming interfaces for third-party connection and service development;
Circular 50/2024/TT-NHNN — safety and security in online service provision;
Circular 17/2024/TT-NHNN — biometric authentication for electronic transactions (face, fingerprint) — a guard against fraud and account takeover.

Together these form the “soft infrastructure” for digital banks and fintechs to connect and operate securely.

4. Pillar 4: Foreign ownership limits (FOL)

Under the 2024 Law on Credit Institutions, foreign investors may own up to 30% of charter capital of a Vietnamese commercial bank (30% FOL). This ceiling shapes every bank M&A deal and every fintech “banking” fundraising plan.

5. Reality check: no standalone digital-bank license yet

A key distinction: “digital bank” is a business model, not a license category. As of 14 October 2026, Vietnam has not issued standalone pure-digital-bank licenses — digital banks operate under the BaaS (Banking-as-a-Service) / partnership model on partner banks’ licenses.

Latest market moves:

MDP/MobiFone licensed for financial switching (License 89/GP-NHNN, 27 November 2025) — the second player after Napas in switching infrastructure;
The Kredivo–Timo deal in 2026 — the fintech–digital bank partnership wave continues.

6. What fintech businesses should prepare

Identify your pillar: payment intermediary (Decree 52/2024 license), sandbox solution (Decrees 94/2025 + 382/2026), or services on Open API rails — each has different procedures.
Use the loosened sandbox: with Decree 382/2026, dossier and personnel barriers are lower — a good time to file trial proposals, especially for credit scoring and P2P lending.
Build security in from day one: meet Circular 50/2024 (security) and Circular 17/2024 (biometrics) in product design, not as afterthoughts.
Price the 30% FOL into your capital structure: later fundraising rounds, ESOPs, and M&A must stay within the foreign ownership ceiling.

7. Frequently asked questions

Does Vietnam have a standalone digital-bank license?

Not yet (as of 14 October 2026). Digital banks operate via BaaS/partnerships on partner banks’ licenses.

What’s new in the 2026 banking sandbox?

Decree 382/2026 (~October 2026) eases the sandbox: multi-channel filing, SBV reuse of digital data (no re-submission), eased personnel conditions, no more board/GMS resolution requirement.

How much of a Vietnamese bank may foreigners own?

Up to 30% of a commercial bank’s charter capital (2024 Law on Credit Institutions).

What is the minimum capital for an e-wallet license?

VND 50 billion (e-wallets, payment gateways); VND 300 billion (switching, clearing) — per Decree 52/2024/ND-CP.

8. Legal bases (as of 14 October 2026)

Law on Credit Institutions 32/2024/QH15 (1 July 2024), amended by Law 96/2025/QH15 (15 October 2025).
Decree 52/2024/ND-CP (1 July 2024) — payment intermediaries, e-money.
Decree 94/2025/ND-CP (1 July 2025) + Decree 382/2026/ND-CP (~October 2026) — banking sandbox.
Circular 19/2026/TT-NHNN (10 June 2026) — sandbox procedure decentralization.
Circular 64/2024/TT-NHNN (Open API); 50/2024/TT-NHNN (e-transaction security); 17/2024/TT-NHNN (biometric authentication).

The sandbox framework is still being completed; fintech businesses should follow further SBV guidance and consult counsel before filing.

Contact us

FLAT Law Firm advises fintechs and digital banks on payment intermediary licensing, sandbox applications, Open API/security compliance, and capital structuring within the FOL ceiling. Reach us via our contact page.

Transparency note — FLAW AI Legal Council: This article was prepared by the FLAW AI Legal Council and has not been reviewed by a human lawyer. It is general information and does not replace legal advice for specific cases.

This article is awaiting review by the QA Council.