Peer-to-peer lending once boomed in Vietnam with no dedicated legal frame, and more than a few platforms collapsed with lenders’ money. From 1 July 2025, P2P lending has its first legal corridor: the banking-sector sandbox pilot mechanism — but the door opens for a very narrow group of operators.
Applicable legal frame
- Decree 94/2025/ND-CP on the controlled testing mechanism in banking (effective 1 July 2025): P2P lending is one of three pilotable solutions, with a maximum two-year test period.
- Operator conditions in Decree 94/2025/ND-CP: the P2P provider must not be foreign-invested, must not lend itself, must not guarantee, and customers are only Vietnamese organisations and citizens.
- Article 468 of Civil Code 2015 and the Law on Credit Institutions 32/2024/QH15: the 20 percent yearly agreed-interest ceiling and the lending boundary for non-credit institutions.
Practical risks
The largest legal risk sits outside the sandbox: a P2P platform operating without testing approval can be treated as unlicensed financial business, while platform interest rates remain capped by the civil interest ceiling of Article 468 of Civil Code 2015 at 20 percent per year unless relevant law provides otherwise, and regular profit-seeking lending by a non-credit institution hits the boundary of the Law on Credit Institutions 32/2024/QH15. Investors must therefore distinguish a technology intermediary connecting lenders and borrowers from an actual lending institution: the sandbox legalises only the intermediary model within approved limits.
In-depth analysis
Decree 94/2025/ND-CP on the controlled testing mechanism in the banking sector, effective 1 July 2025, lists exactly three sandbox-eligible solutions: credit scoring, open API data sharing and peer-to-peer lending. For P2P lending the decree sets hard conditions: the solution provider must not be a foreign-invested enterprise; it must not lend or borrow itself on its own platform; it must not guarantee customers’ repayment obligations; it must not serve pawnshop companies; participating customers must be organisations established in Vietnam or Vietnamese citizens, and all transactions are in Vietnamese dong. Testing lasts at most two years within the scope the State Bank approves for territory, limits and customer numbers. The platform must connect customers’ payment accounts at banks and carry data-protection and reporting duties toward the regulator throughout the test. This means a foreign-operated P2P model cannot join the sandbox at present; foreign investors wanting exposure must consider structures fully compliant with these limits rather than expecting a standalone P2P licence outside the sandbox.
Recommended actions
- Check the ownership structure: the P2P operator must have no foreign investment before filing to join the sandbox.
- Design the platform to never become the lender in either direction: no self-lending, no guarantees, with funds flowing through customers’ bank accounts.
- Build the end-of-test scenario and the handling of the outstanding loan book when the two-year sandbox term expires.
Questions clients often ask
Is peer-to-peer lending currently lawful in Vietnam?
On this question, P2P lending is lawful only inside the controlled testing mechanism of Decree 94/2025/ND-CP; there is no standalone P2P licence outside the sandbox. Before signing or filing anything on P2P lending sandbox Vietnam, the company should verify this point once more.
May a foreign-invested company operate a P2P platform?
It is important to distinguish: The P2P solution provider must not be foreign-invested under the sandbox decree’s operator conditions. In applying this to P2P lending sandbox Vietnam, read the point together with its accompanying conditions, not in isolation.
May a P2P platform guarantee loans for its customers?
Under the current frame, No: the platform may not guarantee customers’ repayment and may not lend itself on its own platform. This point needs updating when the company changes its model in relation to P2P lending sandbox Vietnam.
How long does P2P lending testing in the sandbox last?
In day-to-day handling, Testing lasts at most two years within the territory, limits and customer numbers approved by the State Bank. The company should put P2P lending sandbox Vietnam on its annual compliance review calendar.
What structure should a foreign investor consider to join Vietnam’s P2P field?
Because the P2P lending provider in the sandbox must not be foreign-invested, a foreign investor should consider a technology-supplier or support-partner role for a wholly domestic operator, with a contract clearly drawing the no-lending and no-guarantee boundary, rather than expecting a standalone P2P licence outside the testing mechanism.
This article has been quality-reviewed by the FLAW AI Legal Council