The controlled testing mechanism (Sandbox) in the banking sector was once expected to be a "launch pad" for innovation. However, after nearly a year of actual implementation (from July 1, 2025), barriers from cumbersome administrative procedures (TTHC) and young personnel of startups have unintentionally reduced the timeliness of technology solutions.
To turn institutions into national competitive advantages, the State Bank of Vietnam (SBV) has chaired the drafting of the Decree amending and supplementing Decree 94 with comprehensive legal thinking.
Pushing the progress" of appraisal: Reducing processing time by up to 40%
The core and most noteworthy point for the financial technology community in this draft is the commitment to drastically reduce the processing time of administrative procedures.
For ordinary Sandbox registration dossiers, the appraisal time is proposed to be shortened from 90 working days to 80 days (equivalent to 54.35 working days), achieving an impressive reduction rate of up to 39.6%.
To synchronize with this tightened timeline, the time for collecting opinions and feedback from relevant ministries and sectors has also been shortened from 15 working days to only 10 days (or 7 days depending on the case).
Procedures such as adjusting solutions, stopping trials or issuing completion certificates are all tightly scheduled from 30 working days down to 25 working days.
Terminating "sub-licenses", maximizing digital data application
Another very bold reform thinking of management agencies is to completely eliminate formalistic dossier components, shifting from a demanding mechanism to data self-interconnection and self-responsibility.
Businesses participating in Sandbox no longer have to submit Resolutions approving Projects or Company Charters when carrying out procedures. Instead, the State Bank is responsible for proactively exploiting and using information from national and specialized databases such as data on diplomas, certificates, criminal records or business registration to replace paper documents.
At the same time, the qualifications requirements for executives are also expanded to practical industries such as finance, banking, accounting, auditing, payment intermediaries, and the criteria are changed from "and" to "or" (or) to flexibly recruit talented generals for Fintech companies.
The actual appraisal in the past time shows that creative solutions have no legal precedent to directly regulate, while the participating organizations are mostly young startups, without a seasoned personnel apparatus, so the dossiers are inevitably error-prone.
Current regulations put businesses in a difficult position when only allowing explanation and completion of dossiers once, if not met, they will be returned and have to start over, which is very time-consuming.
To award "lifebuoys" to businesses, the new draft increases the number of times allowed to submit explanations and complete dossiers to 2 times for registration procedures to participate. In particular, for procedures for adjusting or stopping trials, the draft completely removes the limit of the number of times, creating maximum conditions for organizations to proactively complete dossiers without being squeezed by pressure.
