Ho Chi Minh City, 06 May 2026
Decree No. 323/2025/ND-CP sets out the strategic direction for the development of the Vietnam International Financial Center in Da Nang City (“VIFC Da Nang”) as, among others, a controlled testing platform for new financial models, with a particular focus on pioneering and scaling digital asset products, digital payments, and specialized trading platforms and exchanges. Under this strategic vision, the VIFC Da Nang is not conceived as a traditional financial hub centered on physical infrastructure; rather, it is positioned as a large-scale regulatory sandbox designed to foster financial innovation, particularly in the fintech and digital asset space.
Legal Framework Support
To establish a solid foundation for the sandbox, the relevant legal framework has been developed along two key dimensions: (i) substantive legal recognition at the central level, and (ii) the delegation of regulatory authority to local government.
From a substantive law perspective, the recognition of digital assets and emerging financial technologies is evidenced by the issuance of the Law on Digital Technology Industry 2025 and Resolution No. 05/2025/NQ-CP on the pilot implementation of the crypto-asset market in Vietnam (“Resolution 05”). In particular, Resolution 05 establishes a controlled regulatory environment that enables the testing and commercialization of new financial models, alongside the development of an organized crypto-asset market allowing investors to trade digital assets and access related services. This framework serves as a foundational layer for the VIFC Da Nang sandbox, where innovative business models that may not yet fully align with existing legal classifications can be tested under regulatory supervision.
To a regulatory authority perspective, Resolution No. 136/2024/QH15 of the National Assembly (“Resolution 136”) provides Da Nang with delegated powers to pilot specific policy mechanisms, including the implementation of sandbox frameworks in emerging technology sectors such as blockchain and digital assets. Pursuant to this delegation, the Da Nang People’s Council issued Resolution No. 55/2024/NQ-HDND, which sets out detailed criteria, conditions, and procedures for the selection, registration, appraisal, and licensing of controlled pilot projects within the city. This regulatory authority has been further reinforced by Resolution No. 222/2025/QH15 (“Resolution 222”) and Decree No. 324/2025/ND-CP, which specifically empower the governing body of the VIFC Da Nang (under the Da Nang People’s Committee) to promulgate and implement controlled financial sandbox policies applicable to technologies, products, services, and business models not yet addressed under existing laws, thereby significantly expanding regulatory flexibility at the VIFC level and facilitating the development of more tailored sandbox mechanisms. In parallel, Resolution 136 (with a city-wide scope) and Resolution 222 (with a VIFC-specific scope) collectively establish an enabling legal corridor for Da Nang to operationalize the sandbox framework, positioning the city, and in particular the VIFC, as a flexible and controlled testing ground for fintech and digital asset innovations.
Taken together, this dual-layered framework provides both the legal substance and institutional capacity necessary for sandbox implementation. In this context, Da Nang in general, and the VIFC Da Nang in particular, are no longer merely pilot initiatives but are increasingly equipped to operate as scalable, jurisdiction-level sandboxes. With both regulatory foundations and implementation authority in place, VIFC Da Nang is well-positioned to extend beyond fintech applications and serve as a controlled testing ground for more sophisticated capital market innovations, including new asset classes, trading mechanisms, and market infrastructure.
Outlook and Market Developments
With policy support in place, Da Nang has already approved several sandbox programs, particularly in the fintech sector, such as “Basal Pay Software” developed by Alphatrue Solutions JSC, or the “MIMO Solution” – a non-custodial intermediary platform facilitating the conversion between digital assets (USDT) and fiat currency (VND) – implemented by Dragon Lab JSC. Notably, PayD has also been officially admitted into the VIFC Da Nang ecosystem, becoming one of the first fintech platforms to pilot the use of digital asset payments in the tourism and consumer sectors under a controlled sandbox mechanism. In parallel, a number of additional fintech and digital asset solutions are currently under review for approval.
These positive developments in the fintech sector suggest that extending similar sandbox mechanisms to the pilot implementation of a regulated crypto-asset market is increasingly feasible. In particular, the rollout of a sandbox framework for crypto assets, or even pilot applications involving digital currencies, may materialize in the near term within the VIFC Da Nang. In this context, the VIFC Da Nang is well-positioned to evolve in line with its strategic direction as a large-scale, controlled sandbox for digital finance and broader financial market innovation.
