State Bank of Vietnam issues P2P lending sandbox rules with VND 100 million borrower cap and CIC connectivity requirements

The State Bank of Vietnam has issued two decisions to operationalise the controlled testing mechanism for peer-to-peer (P2P) lending under Government Decree 94/2025/ND-CP, which took effect on 1 July 2025. The measures set borrower exposure limits for P2P lending solutions in the sandbox and establish requirements for participating firms to connect to and report data through Vietnam’s National Credit Information Centre (CIC). Decision 2866/QD-NHNN caps a borrower’s maximum outstanding balance at VND 100 million per P2P lending solution, and sets an aggregate cap of VND 400 million across all P2P lending solutions participating in the controlled testing mechanism. Decision 2970/QD-NHNN sets guidance for connection, reporting and credit information checks between P2P firms and the CIC, including technical connection conditions, required data fields, provision deadlines and reporting frequency, and the rights and obligations of sandbox participants when connected to the CIC; the framework is intended to support monitoring of the per-borrower caps and enable provision of borrower information to lenders where borrower consent is obtained in line with applicable law. The two decisions are positioned as the legal basis for organisations seeking to register for the controlled testing mechanism to prepare the necessary technical set-up and governance and operational capabilities for running P2P lending solutions.