The "Peer-to-Peer (P2P) Lending" Trial Mechanism

Decree No. 94/2025/NĐ-CP, issued on April 29, 2025, and effective from July 1, 2025, regulates the controlled trial mechanism in the banking sector. This decree aims to facilitate the implementation of new financial technology (Fintech) products, services, and business models in a safe and efficient manner, with a specific focus on peer-to-peer lending.

The introduction of this controlled trial mechanism allows the state to assess risks and refine the legal framework for peer-to-peer lending activities, ensuring suitability and preventing the emergence of unregulated models (informal credit) that could harm citizens. Concurrently, it encourages innovative financial practices, leveraging technology to directly connect lenders and borrowers, thereby enhancing access to capital for individuals and small businesses and optimizing idle funds in society.

Key provisions of the peer-to-peer lending mechanism under Decree 94 include:

CONTENTS	REGULATIONS
Definitions	Peer-to-Peer Lending Company: A Fintech company that provides peer-to-peer lending solutions to customers. Fintech Company (Financial Technology Company): A non-credit institution and non-foreign bank branch that holds a valid business registration/license in Vietnam and independently offers Fintech solutions or collaborates with credit institutions/foreign bank branches to bring these solutions to the market. Peer-to-Peer Lending Solution: A technology-based solution provided by a peer-to-peer lending company that facilitates information connection and contract execution on a digital platform between borrowers and lenders. The currency used in peer-to-peer lending solutions is Vietnamese Dong. Customer: An organization or individual that enters into a contractual relationship and directly uses the Fintech solution of an entity participating in the trial mechanism.
Trial Duration	Maximum of 2 years from the date the State Bank of Vietnam (SBV) issues the Certificate of Participation in the trial mechanism. Can be extended no more than once per extension, and up to 2 extensions in total.
Scope of the Trial	Limited to the territory of Vietnam; cross-border trials are not permitted. Participating organizations may only offer Fintech solutions within the scope specified in the Certificate of Participation in the trial mechanism.
Conditions for Participation	Must be a legally established and operating legal entity in Vietnam, excluding foreign-invested enterprises. Must not be undergoing processes of division, separation, merger, acquisition, conversion, dissolution, or bankruptcy under the law. The legal representative and General Director/Director must hold a university degree or higher in Economics, Business Administration, Law, or Information Technology, have at least 2 years of management experience in the financial-banking sector, be a Vietnamese national, with no criminal record and no record ofadministrative violations in the fields of finance, banking, or cybersecurity. Not simultaneously be the owner or manager of businesses providing financial, banking, pawnshop, or multi-level marketing services. The Fintech solution must meet the following criteria: (i) falls under areas not yet clearly guided by current regulations; (ii) innovative and creative in nature; (iii) delivers benefits and added value; (iv) has an established risk management legal framework, including contingency and consumer protection plans; (v) feasible for market deployment after the trial period. Must have measures to determine and manage the maximum outstanding loan amount per borrower using its solution. (The Governor of the SBV will determine the maximum outstanding loan for any borrower across all participating peer-to-peer lending solutions.) Loan disbursement, interest, and fee payments must be made through the customer’s payment account or e-wallet. Must have mechanisms to ensure that the contract duration between borrower and lender does not exceed 2 years. IT systems and data storage must be located within the territory of Vietnam.
Application Procedure for Participation in the Trial Mechanism	Step 1: Application Submission Organizations submit applications to the SBV’s One-Stop Service division. Within 5 working days, the SBV issues a written confirmation of receipt of a valid application or requests additional documents. Step 2: Application Appraisal Within 90 working days, the SBV, in collaboration with relevant ministries, appraises the application (including on-site appraisal if necessary). If additional clarification is required, the SBV will request a one-time revision within 30 working days. Step 3: Issuance of Certificate of Participation Upon completion of the appraisal, if the application meets the required conditions, the SBV will issue a Certificate of Participation in the trial mechanism. If rejected, a written explanation will be provided. Step 4: Implementation of the Peer-to-Peer Lending Solution Within 90 days from the issuance of the Certificate, the organization must launch its peer-to-peer lending solution. Failure to do so without a force majeure reason will result in the revocation of the Certificate.
Reporting and Information Provision	Participating organizations are required to submit regular reports (quarterly) or provide ad-hoc reports to the SBV detailing the trial progress, emerging risks, and trial results. At least 90 days prior to the end of the trial, participating organizations must submit a Trial Outcome Evaluation Report to the SBV in accordance with Decree 94. P2P lending companies are also responsible for reporting customer credit information (including both borrowers and lenders) to the Credit Information Center (CIC) as per the SBV Governor’s decisions.
Conclusion of the Trial Period	Based on the Trial Outcome Evaluation Report, the SBV will decide on one of the following actions: Terminate the trial and revoke the Certificate of Participation. Extend the trial period. Issue a Certificate of Completion, allowing the solution to be officially launched in the market.