P2P lending in Vietnam: current legal framework and licensing

For years, peer-to-peer lending in Vietnam lived in a grey zone: technology platforms connected lenders and borrowers with no licence available to obtain. From 1 July 2025 the picture changed in one important respect, when Decree 94/2025/ND-CP opened a controlled testing mechanism (sandbox) in the banking sector, with P2P lending as one of three testable solutions. A sandbox, however, is not a standing business licence, and it is closed to one specific group of investors.

The current framework: a sandbox instead of a grey zone

Decree 94/2025/ND-CP on the controlled testing mechanism in the banking sector, as amended by Decree 382/2026/ND-CP effective from 6 October 2026, allows testing of three fintech solutions: credit scoring, data sharing via open APIs and peer-to-peer lending. Participants need a certificate of sandbox participation from the State Bank of Vietnam, with a maximum testing period of two years and customer scope and transaction values limited to the approved plan.

In the tested model, the P2P solution provider is only a technology platform that connects information and supports contract formation between lenders and borrowers, with transactions in Vietnamese dong. The provider may not itself secure customers’ loans, may not act as a customer on its own platform and may not serve pawnshops. Lenders and borrowers inside the sandbox are limited to legal entities established in Vietnam and Vietnamese nationals.

The decisive point for foreign investors

Sandbox conditions require the P2P solution provider to be an enterprise lawfully established and operating in Vietnam that is not a foreign-invested enterprise. This is a direct barrier: a foreign fintech group cannot place its Vietnamese subsidiary into the P2P sandbox, and no other standing licensing route exists for this activity outside the sandbox at present.

The consequence is that any P2P platform marketing in Vietnam without a sandbox participation certificate operates outside the legal framework, exposed to being treated as unlicensed banking activity or unlawful capital mobilisation depending on its actual structure. Foreign investors who want exposure to Vietnamese consumer credit must use genuinely licensed channels: a licensed finance company, a bank, or technology cooperation with an entity approved for testing within permitted limits.

User risks and the outlook for a standing framework

For lenders on a platform, the core risk is that a peer-to-peer loan is not a bank deposit: it carries no deposit insurance, and a sandbox platform is forbidden from guaranteeing loans. When a borrower defaults, the lender bears direct credit risk, and recovery depends on the platform’s debt handling mechanism and ordinary civil procedures.

Looking ahead, results from the maximum two-year testing period will ground the regulator’s decision on whether to build a standing legal framework for P2P lending. Companies interested in this space should track sandbox entry conditions and evaluation outcomes rather than launching off-framework models, because a compliance record from the testing phase will likely be an advantage when a standing framework arrives.

Frequently Asked Questions

What is the current legal framework and licensing for P2P lending in Vietnam?

The current framework for P2P lending is the banking sandbox under Decree 94/2025/ND-CP, as amended by Decree 382/2026/ND-CP. No standing licensing framework for P2P exists in Vietnam outside this sandbox. Inside it, a platform only provides technology connecting lenders and borrowers in Vietnamese dong, under State Bank supervision, for a maximum testing period of two years.

Is a licence required?

Yes, in the form of a certificate of participation in the controlled testing mechanism issued by the State Bank of Vietnam, rather than a standing P2P business licence. The solution provider must meet conditions on enterprise status, personnel, technology systems and the testing plan, and may operate only within the scope recorded in the certificate. P2P activity outside the sandbox currently has no licensing basis.

What may and may not a P2P platform do?

The platform may connect information between lenders and borrowers and support digital loan contract formation and administration within the approved testing scope. It may not secure customers’ loans itself, may not act as lender or borrower on its own system, may not serve pawnshops and may not run business activities outside the scope of its sandbox participation certificate.

Can foreign investors join P2P lending?

Not through the direct channel: sandbox conditions require the P2P solution provider not to be a foreign-invested enterprise, so a foreign group cannot use its Vietnamese subsidiary to operate P2P lending. Foreign investors seeking Vietnamese consumer credit exposure must choose licensed channels such as a finance company or a bank, or technology cooperation with a domestic entity approved for testing.

Bottom line for fintech investors

P2P lending in Vietnam now has a framework, but it is a controlled testing framework whose entry gate is limited to companies without foreign capital. Every P2P model outside the sandbox lacks a legal basis at present, and that is the first point to check before any investment or partnership decision.