Vietnam Fintech Guide

Introduction

Fintech, short for financial technology, is witnessing rapid growth in Vietnam, capturing the interest of both domestic and foreign investors. Since its emergence in early 2018, the Fintech industry has significantly impacted the Vietnamese market, although it remains in the preliminary stages of development compared to other ASEAN countries.

As a participant in several FTAs, including the WTO, the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CPTPP), the EU-Vietnam Free Trade Agreement (EVFTA), and the Vietnam-Japan Economic Partnership Agreement (VJEPA), Vietnam engages actively in international trade. However, these agreements do not automatically grant foreign investors access to the Vietnamese market. Notably, the EVFTA and CPTPP recognize Fintech services as “new financial services”, but Vietnam reserves the right to regulate these services through pilot programs. These programs allow Vietnam to carefully control the number of financial service providers and limit the pilot programs’ scope, serving as a controlled environment for testing new Fintech products.

To date, Vietnam has yet to develop clear and robust legislation regulating Fintech activities. The payment segment of fintech (including e-wallets) dominates the Vietnam Fintech market largely due to clear regulations. Other segments (such as P2P lending) have long waited for a regulatory sandbox that would facilitate their growth and integration into the broader financial system.

This guide aims to provide an overview of the regulatory landscape for Fintech in Vietnam, and focuses on several succinct legal issues for popular business models, at the time of writing. The guide is structured as follows:

  • Executive Summary: A concise overview of the key findings.
  • Fintech Popular Business Models and Activities: An examination of popular Fintech business models, including P2P lending, buy-now-pay-later, wealth management, e-payment services (including e-wallets), cryptocurrency, Insurtech, and digital credit scoring. We also analyze how investment restrictions and local industry regulations may impact these businesses.
  • Implications of Additional Regulations: A review of three non-financial service laws with significant implications, covering data protection and cybersecurity, anti-money laundering, and electronic transactions.
  • Sandbox Mechanism: An assessment of the draft Government decree aimed at regulating previously unregulated Fintech forms.

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