On 6 October 2026, the Government issued Decree 382/2026/ND-CP amending the controlled testing mechanism (sandbox) for banking-sector fintech — effective immediately upon signing, with no transition period. The amendments focus on relaxed personnel requirements, reduced dossiers, and shifting the burden of proof from enterprises to regulators through national database interoperability.
1. Legal basis
- Decree 382/2026/ND-CP — signed and effective 6 October 2026; amending Decree 94/2025/ND-CP on the controlled testing mechanism in banking.
- Regulator: the State Bank of Vietnam.
- Note: enterprises preparing dossiers should re-check their paperwork immediately, as there is no transition period.
2. What is the controlled testing mechanism?
The sandbox allows fintech companies to test new solutions in a supervised environment overseen by the State Bank before wide rollout. A fintech company is considered for a testing participation certificate when its solution meets the criteria in Clause 1, Article 8 of Decree 94/2025/ND-CP plus legal-person and personnel conditions.
3. Relaxed requirements for fintech company leaders
Point b, Clause 2, Article 8 now uses “or” instead of “and”:
- Before: the legal representative / General Director (Director) had to simultaneously hold a university degree in economics, business administration, law or IT and have at least 2 years of managerial experience in finance/banking.
- From 6 October 2026: only one of the two is required — (a) a university degree in economics, business administration, law, IT, finance, banking, accounting or auditing; or (b) at least 2 years of managerial experience in finance, banking, payment intermediation or IT; and not falling into prohibited categories.
Young founders with matching degrees but less than 2 years of managerial experience may now front a sandbox application.
4. Reduced application dossiers
- Clause 3, Article 9 abolished: fintech companies no longer submit resolutions of the members council, board of directors, general shareholders meeting or owner documents approving the fintech solution proposal.
- Amended Clause 4, Article 9: the solution proposal must present a simulation model or demo, target customer groups, technical documentation on information-system security by level, and the criteria in Appendix II.
- Personnel dossiers (Clause 6, Article 9): only a curriculum vitae (issued within 6 months) plus proof of qualifications or position/tenure confirmation for leaders.
5. The State Bank now mines national databases itself
The most notable institutional reform: the State Bank must proactively exploit the national database and specialized databases for integrated documents — criminal records, diplomas/certificates, enterprise registration, investment registration. Enterprises need not re-submit documents the regulator can retrieve; supplementary filing is required only where retrieval fails or data is incomplete/inaccurate.
6. More filing channels
Applications for participation, solution adjustments, suspension/extension of testing, and completion certificates may be filed via: public postal service; hired service providers or authorization; in person at the State Bank one-stop unit; or online via the National Public Service Portal.
Frequently asked questions
Q: Our fintech startup director has a relevant degree but no managerial experience. May we join the sandbox?
A: Yes, if the director holds a university degree in one of the listed fields (economics, business administration, law, IT, finance, banking, accounting, auditing) and is not in a prohibited category.
Q: We filed before 6 October 2026. What happens?
A: Decree 382 took effect on signing with no transition rules; enterprises with dossiers in preparation should re-check against the reduced paperwork list.
Q: Must we still submit copies of diplomas and establishment licenses?
A: No, if the State Bank can retrieve them from national/specialized databases. Supplementary copies are required only where retrieval fails or data is inaccurate.
Legal sources
- Decree 382/2026/ND-CP (effective 6 October 2026) — amending Decree 94/2025/ND-CP
- Decree 94/2025/ND-CP (Articles 7, 8, 9; Appendix II) — controlled testing mechanism in banking
Transparency note: This article was prepared and reviewed by the FLAW AI Legal Council (an artificial-intelligence council), not by a human lawyer. It is for general information only and does not constitute legal advice for any specific case. This article is pending QA Council review.