For Fintech and Digital Asset Firms: Sandboxes, Licensing, and the Path to Market in the VIFC

Why the VIFC matters for digital asset firms#

Vietnam presents a paradox for digital asset companies. The country has one of the highest rates of cryptocurrency adoption in the world — consistently ranking in the top ten on Chainalysis's Global Crypto Adoption Index — yet it has no legal framework governing digital asset issuance, trading, or custody. Crypto is not banned, but it is not regulated either. It exists in a grey zone where consumer activity is widespread but institutional participation is impossible.

The VIFC resolves this paradox within its boundaries. Resolution 222 explicitly lists fintech and digital assets as a priority sector. The implementing decrees create two distinct pathways for digital asset activity: a sandbox mechanism for novel products and business models, and a direct licensing pathway for activities that fall within defined categories.

For firms that have spent years navigating regulatory uncertainty across Asia — watching Hong Kong's licensing regime take shape, monitoring Singapore's tightening MAS framework, observing Dubai's VARA system mature — the VIFC represents a new option. Not necessarily a better one in every dimension, but a different one, with its own advantages and constraints.

The two pathways#

Pathway 1: The regulatory sandbox#

The sandbox is the VIFC's mechanism for activities that do not yet have a full regulatory framework. It is established under Decree 324 and Article 24 of Resolution 222.

What a sandbox is. A controlled testing environment where firms can deploy products and services with real users, under modified regulatory requirements, for a defined period. The sandbox imposes boundaries — limits on the number of users, transaction volumes, or product scope — while providing regulatory cover that would not exist outside the VIFC.

What the sandbox is not. It is not a permanent operating licence. It is not a free pass to do whatever you want. And it is not a marketing label — the VIFC sandbox has defined entry criteria, operating conditions, reporting obligations, and exit procedures.

Who needs the sandbox. Firms whose products or business models fall outside the categories for which the VIFC has issued full licensing rules. In practice, this means most novel digital asset activities:

• Tokenised securities platforms
• Stablecoin issuance and management
• DeFi protocols offering lending, borrowing, or yield products
• Decentralised exchange (DEX) infrastructure
• Cross-border payment systems using blockchain rails
• Digital identity and KYC/AML infrastructure
• AI-driven financial advisory or trading systems

How the sandbox works. The process, based on the framework in Decree 324, follows a structured sequence:

1. Application — submit a proposal to the IFC Management Authority describing the product, technology, target users, risk assessment, and consumer safeguards
2. Assessment — the Management Authority and Supervisory Authority evaluate the proposal against admission criteria (innovation, viability, consumer protection, systemic risk)
3. Admission — if approved, the firm receives sandbox authorisation with defined parameters: duration, user limits, geographic scope, reporting requirements
4. Operation — the firm operates within the sandbox boundaries, providing regular reports to the Supervisory Authority
5. Evaluation — at the end of the sandbox period (or earlier if conditions warrant), the Supervisory Authority assesses whether the product should graduate to full licensing, be modified, or be discontinued
6. Graduation or exit — successful products receive full VIFC licensing; unsuccessful ones wind down under the Supervisory Authority's oversight

The specific admission criteria, duration limits, and reporting formats have not yet been published. The IFC Management Authorities are expected to issue detailed sandbox operating procedures in the coming months.

Pathway 2: Direct licensing#

Some fintech and digital asset activities fall within categories that already have regulatory frameworks within the VIFC — either because they are variations of traditional financial services or because the decrees specifically address them.

NFT trading. Decree 330 explicitly permits commodity exchanges within the VIFC to trade cultural and artistic products structured as non-fungible tokens. This is a direct licensing pathway — NFT exchange operators apply for a commodity exchange licence, not sandbox admission.

Payment services. Digital payment systems that operate within the banking and FX framework of Decree 329 and Circular 72 can seek direct licensing as payment service providers.

Regtech and compliance technology. Firms providing regulatory technology, compliance monitoring, or AML/CFT solutions to VIFC members can operate as licensed professional service providers without the sandbox.

Data analytics and market infrastructure. Firms providing market data, analytics, rating services, or index calculation can seek direct licensing under the market infrastructure category.

The distinction matters for planning. Sandbox admission involves operating under constraints (time limits, user caps, modified requirements) with the goal of proving the model. Direct licensing involves meeting full requirements from day one but without the constraints. Firms should evaluate which pathway applies to their specific product — and in some cases, a firm may use both pathways simultaneously for different products.

What is explicitly on the priority list#

Decree 323 establishes the VIFC's priority sectors, and the fintech and digital asset category is detailed. The following activities are explicitly identified as priorities:

Asset tokenisation#

The conversion of real-world assets — securities, real estate, commodities, intellectual property, receivables — into blockchain-based tokens that can be traded, transferred, and settled on distributed ledger infrastructure. This is one of the highest-profile use cases globally, and the VIFC's inclusion of it as a named priority is a clear signal to tokenisation platforms.

Stablecoins#

Issuance and management of stablecoins — digital tokens pegged to a fiat currency or other reference asset. The presence of Circle (issuer of USDC) and Tether (issuer of USDT) among the VIFC's founding members is not coincidental. The framework is designed to accommodate stablecoin operations, though the specific licensing requirements and reserve management rules will be defined through the sandbox or subsequent regulations.

Web3 and decentralised applications#

Web3-based financial applications, including decentralised autonomous organisations (DAOs) operating in financial services, decentralised identity systems, and blockchain-based governance tools. This is a broad category that reflects the VIFC's ambition to attract the next generation of financial infrastructure, not just the current one.

Decentralised finance (DeFi)#

DeFi protocols — lending, borrowing, yield generation, automated market making, and liquidity provision — are explicitly named as a priority sector activity. This is notable because most jurisdictions either ignore DeFi entirely or regulate it by analogy to traditional finance (often awkwardly). The VIFC's approach of naming DeFi as a priority and routing it through the sandbox creates a more purposeful regulatory pathway.

Digital payment systems#

Blockchain-based payment rails, cross-border remittance systems, and digital wallets. Vietnam has a large remittance market (receiving over $15 billion annually) and a rapidly growing domestic digital payments ecosystem. The VIFC provides a base for firms building payment infrastructure that serves both Vietnamese and regional flows.

Regulatory technology#

Compliance automation, transaction monitoring, identity verification, sanctions screening, and reporting tools. As the VIFC's ecosystem grows, demand for regtech solutions will grow with it — creating a market for firms that can serve both VIFC members and, potentially, Vietnam's broader financial sector.

Artificial intelligence in financial services#

AI-driven trading systems, robo-advisory platforms, credit scoring models, fraud detection, and algorithmic compliance tools. The intersection of AI and financial services is a global growth area, and the VIFC's framework accommodates it within the fintech priority sector.

Who has already committed#

The VIFC's founding member list includes several firms that signal the direction of digital asset activity:

• Binance — the world's largest cryptocurrency exchange by trading volume. Its presence as a founding member suggests the VIFC will host regulated crypto exchange activity, likely through the sandbox initially.
• Circle — the issuer of USDC, the second-largest stablecoin by market capitalisation. Circle's involvement signals that stablecoin issuance and management will be accommodated within the framework.
• Tether — the issuer of USDT, the largest stablecoin globally. Like Circle, Tether's founding membership points to stablecoin operations as a core VIFC activity.
• Global On-chain Economic Alliance — a consortium focused on blockchain-based economic infrastructure.
• Viettel — Vietnam's largest telecommunications company, with significant digital payments and fintech operations.

The combination of global crypto-native firms and major Vietnamese technology companies suggests the VIFC is positioning itself as a bridge — connecting international digital asset expertise with Vietnamese market access and regional distribution.

Da Nang versus Ho Chi Minh City#

The VIFC operates under a "one centre, two locations" model, and the two cities have different orientations for fintech and digital assets.

Da Nang: the sandbox and innovation hub#

Da Nang (300 hectares) is explicitly positioned as the VIFC's innovation centre. For fintech and digital asset firms, Da Nang is likely the entry point:

• Sandbox operations — Da Nang is the primary venue for sandbox testing and experimentation
• Innovation ecosystem — lower operating costs, a growing tech talent pool, and government investment in digital infrastructure
• Lighter footprint — suitable for early-stage firms, R&D operations, and small teams testing products before scaling
• Lifestyle — a coastal city with significantly lower living costs than HCMC, increasingly attractive to digital nomads and remote-first teams

Ho Chi Minh City: the scaling venue#

HCMC (898 hectares in Thủ Thiêm, Cần Giờ, and surrounding areas) is the comprehensive financial hub. For fintech firms, HCMC becomes relevant when:

• Products graduate from the Da Nang sandbox and require full licensing
• The firm needs proximity to banking counterparties, institutional investors, and capital markets infrastructure
• Operations require deep talent pools in finance, compliance, and operations
• The business model involves integration with traditional financial services

The pathway for many fintech firms may be: sandbox in Da Nang → prove the model → scale in HCMC. But this is not mandatory — firms can operate in either or both locations from inception.

The regulatory comparison#

How does the VIFC stack up against other jurisdictions competing for fintech and digital asset firms?

Versus Dubai (VARA + DIFC)#

Dubai has moved aggressively on digital asset regulation. VARA (Virtual Assets Regulatory Authority) provides a comprehensive licensing framework across mainland Dubai, while the DIFC's Innovation Testing Licence offers a sandbox pathway. The VIFC's advantage: lower operating costs, lower tax rates (10% CIT vs 9% UAE federal CIT plus potential emirate fees), and access to Vietnam's 100-million-person market. Dubai's advantage: an established and operational regulatory framework, deep liquidity, and a proven track record of attracting global firms.

Versus Singapore (MAS)#

Singapore's Payment Services Act and Digital Payment Token licensing provide clear but increasingly stringent frameworks. MAS has been tightening retail crypto access while maintaining openness to institutional digital asset activity. The VIFC's advantage: the sandbox offers more flexibility for novel models, and operating costs are substantially lower. Singapore's advantage: regulatory maturity, rule of law reputation, established financial ecosystem, and global connectivity.

Versus Hong Kong (SFC + HKMA)#

Hong Kong has introduced a licensing regime for virtual asset trading platforms under the Securities and Futures Commission. The framework is comprehensive but demanding in terms of capital, custody, and compliance requirements. The VIFC's advantage: lower entry barriers, lower costs, and a sandbox that accommodates experimentation. Hong Kong's advantage: deep capital markets, established legal infrastructure, and proximity to mainland China's financial system.

Versus AIFC (Kazakhstan)#

The Astana International Financial Centre has positioned itself as a digital asset hub for Central Asia, with a purpose-built regulatory framework (the AFSA's digital asset rules) and zero CIT/PIT until 2066. The VIFC's advantage: dramatically larger addressable market, stronger economic fundamentals, and better global connectivity. The AIFC's advantage: zero tax, simpler regulatory structure, and a functioning digital asset framework already in operation.

The VIFC is not trying to be the cheapest or the most permissive. Its positioning is: a regulated pathway in a high-growth market — combining sandbox flexibility with long-term incentives and access to a major economy.

Tax and incentive considerations#

For fintech and digital asset firms, the fiscal framework includes:

• 10% CIT for 30 years on profits from VIFC activities in prioritised sectors (which explicitly includes fintech and digital assets)
• 15% PIT cap for employees working within the VIFC — significant for attracting senior engineers, product managers, and compliance specialists
• Withholding tax reductions on payments to non-resident entities
• Import duty exemptions on technology equipment

For early-stage firms, the CIT rate matters less than the PIT cap and the operating cost environment. Vietnam's salary levels for technical talent are a fraction of Singapore, Hong Kong, or Dubai equivalents, and the 15% PIT cap makes it viable to attract senior international hires who would face much higher tax burdens in competing jurisdictions.

What to evaluate before committing#

Is your product sandbox or direct-licence?#

Map your product to the VIFC's categories. NFT exchanges, payment services, regtech, and market data firms may qualify for direct licensing. Tokenisation platforms, stablecoin issuers, DeFi protocols, and novel trading models will likely need the sandbox. Some firms may need both pathways for different products.

What is your timeline?#

The sandbox operating procedures have not been published. Firms that need to launch immediately should consider whether the VIFC's timeline aligns with their own. Firms with a 12-24 month horizon are better positioned — the operating machinery should be substantially in place by then.

What is your market?#

If your target market is Vietnamese retail users, the VIFC may not be your answer — the VIFC's FX liberalisation and regulatory autonomy apply within its boundaries, not across the broader Vietnamese economy. If your target is institutional clients, cross-border flows, or regional distribution from a Vietnamese base, the VIFC is better aligned.

What is your compliance capacity?#

The VIFC's sandbox is not a compliance holiday. AML/CFT obligations apply in full. Reporting requirements will be substantive. The Supervisory Authority will monitor sandbox participants actively. Firms accustomed to operating in unregulated or lightly regulated environments should assess whether they can meet the VIFC's compliance expectations.

What is your exit strategy?#

Sandbox products that do not graduate to full licensing must wind down. Firms should have a plan for what happens if the sandbox evaluation does not go their way — including the ability to migrate operations, return user funds, and exit cleanly.

Practical next steps#

1. Review the legal framework — start with Resolution 222, then read the guides to Decree 329/Circular 72 and Decree 330 to understand the banking, FX, and exchange frameworks your products will interact with
2. Classify your products — determine which pathway (sandbox, direct licence, or both) applies to each product line
3. Engage with the IFC Management Authority — Da Nang for sandbox and innovation activities, HCMC for full-service operations. Early engagement positions you for priority consideration
4. Assess your compliance readiness — AML/CFT policies, risk management frameworks, consumer protection mechanisms, and reporting capabilities
5. Plan your corporate structure — consider whether a new VIFC entity, a branch, or a subsidiary of an existing entity best serves your licensing, tax, and operational needs
6. Monitor regulatory developments — sandbox operating procedures, licensing requirements, and specific digital asset rules are expected in the coming months

"The VIFC is not the only jurisdiction offering a regulated pathway for digital assets. But it may be the only one offering that pathway inside a 100-million-person economy with 7% GDP growth, one of the world's highest crypto adoption rates, and a government that has made financial centre development a national priority."

For the foundational legal framework, see our guide to Resolution 222. For the market infrastructure being built, see our guide to Market Structure and Products. For licensing and membership requirements for all financial institutions, see our guide For Financial Institutions.

This guide was last updated on 14 February 2026. Sandbox operating procedures, digital asset licensing requirements, and specific product approval criteria have not yet been published. We will update this guide as new instruments are issued. For the latest, see our Opportunities section.