Inside Vietnam’s Fintech Sandbox: P2P Lending, Open APIs, and Credit Scoring Go Live

Demand-side conditions help explain why policymakers are putting structure around experimentation. Acclime Vietnam and CEEC describe Vietnam as having a population exceeding 102 million and internet penetration at around 77%, supporting a large base that is increasingly open to online financial services. Ken Research also reports 79.8 million internet users in early 2025, equal to 78.8% of the population. At the same time, Vietnam’s domestic digital payment ecosystem has scaled fast. Mordor Intelligence notes 5.5 billion cashless transactions recorded in Q1 2025, facilitated by NAPAS 247’s real-time QR infrastructure that lowers merchant acceptance costs and expands digital use cases. That context is important because sandbox lending, scoring, and APIs can plug into payment rails people already use.

What Changed: From “Grey Zone” to Regulated Trial

For P2P lending platforms, the core headline is regulatory clarity. Acclime Vietnam and CEEC state that Vietnam moved P2P lending out of a long-standing “grey zone” by introducing the formal regulatory sandbox under Decree 94/2025/NĐ-CP, effective 1 July 2025. They add a practical takeaway for investors: Vietnam is now a “regulated build” opportunity, not a pure speed-to-market play. In other words, entry strategy becomes a structuring and governance question from day one. While the sources refer to caps during the trial period, they emphasize the purpose rather than listing figures: according to SBV, caps are designed to ensure consistent risk-management principles, align with the experimental nature of the sandbox, and limit potential losses for both lenders and borrowers.

Open APIs and credit scoring are not side features in this sandbox design; they are explicitly included categories. The policy direction aligns with a broader market narrative in which payments lead, but infrastructure and lending products expand. Mordor Intelligence reports that digital payments held 71.73% of Vietnam fintech market share in 2025, and mobile applications captured 79.28% share. Ken Research’s Vietnam FinTech APIs and Open Banking market report values that market at approximately USD 16.9 billion, tied to demand for seamless financial services integration. On the lending side, Ken Research’s Vietnam FinTech Lending & P2P market report projects growth from USD 3,750 million in 2025 to USD 8,850 million in 2031, with a 15.37% forecast CAGR in 2026–2031. The sandbox creates a mechanism for these tracks—payments, APIs, scoring, and lending—to connect under supervision.

Operationally, the sandbox also points to how data and verification will work. Acclime Vietnam and CEEC cite Decision 2970/QĐ-NHNN dated 11 August 2025, which sets out detailed rules on data connectivity, reporting, and credit-information verification between P2P lending companies and the National Credit Information Center (CIC). This is the “plumbing” that can make alternative credit models more auditable during the trial phase. For providers, it raises the bar on reporting discipline and governance. For the market, it signals that growth is expected to come with controls, as Vietnam scales innovative models while aiming to protect lenders, borrowers, and overall financial stability.