Peer-to-peer Lending under Regulatory Testing Environment for Institutions: Guidelines for Corporate Lenders
In a strategic move to foster fintech innovation while maintaining financial stability, Vietnam has introduced a regulatory framework for peer-to-peer (P2P) lending. The new rules, outlined in Decree No. 94/2025/ND-CP, took effect on July 1, 2025, and create a dedicated sandbox for domestic fintech companies and licensed credit institutions.
The sandbox allows these firms to pilot their P2P lending solutions under controlled conditions, enabling the government to monitor systemic risks and consumer protection before broader legalization. Participating entities must adhere to strict operational and reporting requirements under the supervision of the State Bank of Vietnam.
Key requirements and limits include:
- Transactions must be conducted in Vietnamese Dong (VND).
- Participants must submit a detailed application dossier in Vietnamese, demonstrating operational capacity, consumer protection commitments, and risk management frameworks.
- The regulatory sandbox model aims to ensure that operations do not threaten financial stability and that strict legal obligations are upheld to protect borrowers and lenders.
While specific quantitative limits on loan sizes or outstanding volumes for P2P platforms in the sandbox have not been detailed, participants must operate within the framework of the sandbox that balances innovation with financial safety.
Potential risks addressed by the regulation focus on financial system stability, consumer protection, and fraud prevention. By restricting foreign investment in P2P players within the sandbox, authorities aim to maintain regulatory control and mitigate money laundering or capital flight risks.
Banks and Vietnamese companies, in their capacity as lenders, may utilize solutions provided by P2P lending companies. However, they should pay special attention to regulations on customer information confidentiality. The sharing and processing of customer data between the lender and the P2P lending company must comply with various laws and regulations.
The three parties involved in P2P lending are the P2P lending company, the lender, and the borrower. The borrower can include legal entities (excluding banks) and individuals who are Vietnamese nationals. Any loan contract entered into on a digital platform participating in the sandbox cannot exceed a term of two years. The contracts must comply with relevant laws.
It's worth noting that the decree does not require P2P companies to establish mechanisms for setting up security for loans, and P2P lending involves indirect participation of a third party, which may make debt recovery uncertain. Lenders should ensure that their lending funds come from lawful sources and that they do not borrow funds in order to lend them out.
Clarity in the legal framework will be a key factor in helping banks and companies gain greater confidence in harnessing the potential of P2P lending solutions, thereby contributing to the sustainable development of Vietnam's fintech ecosystem. However, the absence of detailed regulations governing lending through P2P solutions may necessitate further guidance from the State Bank of Vietnam and other relevant authorities for banks and companies to implement lending via P2P platforms more effectively and safely.
[1] Decree No. 94/2025/ND-CP on the management, provision, and use of electronic payment services and electronic money issued by the State Bank of Vietnam. [2] Circular No. 36/2020/TT-NHNN on the management of internet-based lending activities issued by the State Bank of Vietnam. [3] Official Letter No. 1629/TĐ-NHNN dated August 15, 2025, on the implementation of Decree No. 94/2025/ND-CP on the management, provision, and use of electronic payment services and electronic money issued by the State Bank of Vietnam.
In the regulatory sandbox for fintech companies, firms are permitted to experiment with P2P lending solutions using stringent operational and reporting requirements, as outlined in Decree No. 94/2025/ND-CP. This charter also specifies that transactions must be made in Vietnamese Dong (VND).
To ensure the protection of both borrowers and lenders within the business environment, the State Bank of Vietnam closely monitors the activities of these firms and has put in place measures to mitigate potential risks such as financial system instability, consumer protection, and fraud prevention, including barring foreign investment in P2P players within the sandbox.
