For P2P lending services, to participate in the sandbox, companies are required to, among other things, (i) have measures in place to determine and manage the maximum outstanding debt for each borrower within the P2P lending solution provided by the company, with real-time reporting and information sharing about the borrower through the Vietnam National Credit Information Center; (ii) ensure that disbursement and repayment of loan principal, interest, and fees for customer transactions within the P2P lending solution is carried out via the customer's payment account at a credit institution or foreign bank branch, or via the customer's e-wallet at a licensed IPS provider; and (iii) have measures in place to ensure that the contract term between the borrower and lender using the P2P lending solution participating in the sandbox does not exceed two years (the term of the sandbox is two years). In addition, the sandbox participant must be a 100% local entity (no foreign ownership allowed). There are also strict requirements for the legal representative and general director (or director) of the company.
Additional comments regarding the legal situation for loan-giving-, factoring-, brokerage, finetrading-, and ancillary services or what FinTech’s must be aware of in this business area
Many FinTech activities which have been previously operated in legal "gray zones" like P2P lending and credit scoring must participate in controlled testing mechanisms. This is an opportunity for FinTechs to legitimize their operations, but also requires strict compliance with conditions on technology, information security, risk management, and human resources as required during the sandbox period.
FinTechs must be very careful not to conduct activities that are exclusive to CIs without proper licensing. Many FinTechs choose partnership models with banks or financial companies to provide their services, leveraging partners' licenses while focusing on their technological strengths.
FinTech financial services, especially those involving money flows, must strictly comply with AML/CFT regulations under the Anti-Money Laundering Law 2022 and related guidance documents. Ignoring these regulations may lead to severe penalties.
Economic conditions
Market size for loan-giving-, factoring-, brokerage-, finetrading- and ancillary services and biggest companies in this business area
According to MD Finance, Vietnam’s loan and consumer finance market is experiencing robust growth, driven by strong economic fundamentals, a rising middle class, and rapid digital transformation. As of 2024, the total value of the Vietnam loan market reached approximately USD 643.23 billion, with projections to grow to USD 989.21 billion by 2030 at a CAGR of 13.22%. The consumer finance segment alone is valued at around USD 6 billion.
In addition, according to Research & Market, the largest players in Vietnam’s loan-giving and consumer finance sector include FE Credit, Home Credit, MCredit, HD SAISON, Mirae Asset, Shinhan, SHBankFinance, Viet Credit, Easy Credit, JACCS, and Lotte Finance.