In a significant step toward building and operating a Financial Center, the People’s Committee of Da Nang has issued Decision No. 1181/QĐ-UBND approving a time-limited controlled trial (“sandbox”) for the innovative financial technology solution Basal Pay, developed by AlphaTrue Solutions JSC.

Basal Pay is a blockchain-based application designed to facilitate the exchange of digital assets into fiat currency, such as converting cryptocurrencies like Bitcoin and USDT into Vietnamese đồng (VND). The project has been granted a36-month trial period, operating at two designated sites: the Da Nang Startup and Innovation Support Center, and the Da Nang IT Park – Software Parks No. 1and 2.

The controlled trial will unfold across five structured phases: (i) Initiation and platform development; (ii) Limited pilot testing; (iii)Scaling and expansion; (iv) Comprehensive evaluation; (v) Long-term implementation and commercialization.

This approval not only represents a pilot program but also marks a clear policy shift in Vietnam’s financial center regulatory framework—opening up opportunities for investors and enterprises in the rapidly evolving fintech and digital asset sectors.

Exploring the Official Legal Framework for Sandbox Mechanisms in Vietnam

Under Decree No. 94/2025/NĐ-CP, effective July 1, 2025, Vietnam introduced a sandbox mechanism in the banking sector. This framework allows credit institutions, branches of foreign banks, and licensed fintech companies to test specific financial products and services under the supervision of the State Bank of Vietnam (SBV). The trial period may last up to two years, with the possibility of two extensions of no more than one year each.

However, the decree is limited in scope to three categories: (i) Credit scoring; (ii) Open API-based data sharing; (iii)Peer-to-peer (P2P) lending.

Importantly, Basal Pay’s blockchain technology and digital asset-to-fiat conversion model do not fall within the ambit of this decree.

The application process under Decree 94 is rigorous: applicants must submit comprehensive dossiers to SBV, demonstrating innovation, user benefits, and feasibility. They must also establish robust risk management frameworks, implement measures to mitigate adverse impacts on the banking and monetary system, and put in place strong consumer protection mechanisms. Solutions must undergo internal assessments for operational, functional, and risk dimensions, ensuring market readiness upon completion of the sandbox period.

In addition to Decree 94, two other legal instruments are expected to reshape Vietnam’s sandbox regime:

• The Digital Technology Industry Law, effective January 1, 2026: authorizes controlled trials of digital technology-based products and services across multiple sectors, incorporating liability exemption provisions for regulators and participants.
• The Science, Technology and Innovation Law, effective October 1, 2025: permits sandbox trials for unregulated or unconventional technologies, processes, services, and business models, with a maximum term of three years, renewable once for an additional three years.

Both laws, however, have not yet come into force. For now, Decree 94/2025/NĐ-CP remains the only binding regulation providing detailed conditions, procedures, and authority for sandbox certification in fintech.

So how can fintech applications like Basal Pay, which fall outside the scope of Decree 94/2025/NĐ-CP, still receive approval in Da Nang?

Resolution No. 222/2025/QH15 of the National Assembly, effective from September 1, 2025,establishes a dedicated legal framework for International Financial Centers(IFCs) in Ho Chi Minh City and Da Nang. Accordingly, Article9 authorizes IFC governing bodies to promulgate operational regulations, including sandbox frameworks Article 24 introduces a forward-looking sandbox for fintech and innovation, permitting trials of business models and technologies not yet regulated under Vietnamese law. This sandbox has a broader scope than Decree 94/2025/NĐ-CP, covering blockchain, digital assets, and green finance initiatives.

However, Resolution 222/2025/QH15 does not specify detailed procedures, application dossiers, or approval criteria. Against this backdrop, Da Nang’s approval of Basal Pay demonstrates a pragmatic and flexible regulatory approach, signaling its readiness to embrace novel business models. This move also sets an important precedent, shifting Vietnam’s sandbox regime from a tightly controlled model to a more open and adaptive framework, better suited to the rapid pace of technological change.

Through Basal Pay, Da Nang has clearly showcased the superior position and advantages of a Financial Center compared to the rest of Vietnam, leveraging open policies to attract fintech innovation.

Opportunities for Fintech and Digital Asset Enterprises in Vietnam’s International Financial Center

The official approval of Basal Pay’s trial sends a strong signal to the international investment community: Vietnam’s financial centers are ready to provide a “regulatory laboratory” for fintech innovation.

For startups, this means they no longer need to wait for a fully codified legal regime; instead, they can apply directly for sandbox participation, provided they demonstrate effective risk management and compliance with anti-money laundering (AML) and counter-terrorism financing (CFT) regulations.

With a sandbox framework that explicitly encompasses blockchain, digital assets, and sustainable finance, the Da Nang Financial Center sandbox could become a launchpad for disruptive fintech models. This not only fosters innovation but also attracts venture capital and international partnerships, giving Vietnam a competitive advantage over regional peers that remain cautious toward unconventional financial technologies.

Conclusion

The approval of Basal Pay for trial marks a policy breakthrough, affirming the distinctive regulatory advantages of Vietnam’s financial centers.

In the global race for fintech and digital assets, competitive advantage will accrue to countries that establish transparent and forward-looking sandbox mechanisms. With Basal Pay, Vietnam has sent a clear signal of readiness to compete on the international stage, positioning itself as an attractive financial center for fintech enterprises and global investors alike.