State of open banking vietnam 2025

Key observations

• Effective March 1, 2025, Circular 64/2024/TT-NHNN mandates that banks, including foreign branches, implement open APIs to facilitate secure data sharing—with user consent—across multiple tiers of access

• By July 1, 2025, banks must submit their API catalogs and implementation plans to the SBV

• Full compliance is required by March 1, 2027 

• A draft from July 2024 further clarified these APIs fall into three implementation phases—information query, consent-based access, and full payment initiation—within 12, 18, and 24 months respectively .

Open Banking in Vietnam's Leap: A Digital Financial Frontier in Motion

Vietnam is stepping boldly into the era of open banking, driven by a strategic blend of regulatory foresight, technological infrastructure, and a market hungry for financial inclusion. With the State Bank of Vietnam (SBV) leading the charge, the country's newly enacted Circular 64 and supporting sandbox frameworks are laying the foundation for a secure, interoperable, and inclusive digital financial ecosystem.

This article explores the current state and trajectory of open banking in Vietnam—how it's being structured, the opportunities it creates, the challenges ahead, and what it signals for Southeast Asia’s fintech future.

The Regulatory Engine: Circular 64 and Decree 94

Vietnam’s open banking journey became tangible with the passage of Circular 64/2024/TT-NHNN, which officially came into effect on March 1, 2025. It requires commercial banks and foreign bank branches to expose standardized APIs that allow third parties to access financial data and services—only with customer consent. The objective is to enable secure, user-permitted data flows across platforms, facilitating everything from payments to lending to financial planning.

The circular introduces a phased approach for Open Banking Vietnam,

1. Phase 1: Basic information query APIs (e.g., account balances, transaction history)

2. Phase 2: Consent-driven access and data sharing

3. Phase 3: Payment initiation and financial service orchestration

Banks must submit their open API catalogs and roadmaps to the SBV by July 1, 2025, with full compliance required by March 1, 2027. These deadlines offer a clear runway for planning, testing, and gradual deployment.

Parallel to this, Decree 94/2024 launches Vietnam’s national fintech sandbox. Beginning in July 2025, this initiative allows approved fintechs and financial institutions to test open API products in a controlled environment. The sandbox is SBV-supervised and operates for up to two years per participant. This signals Vietnam's commitment to innovation—but with safeguards around consumer risk, data protection, and system stability.

A Security-First, Standards-Based Approach

Vietnam is learning from the successes and mistakes of global open banking markets. Circular 64 specifies rigorous technical standards:

• Authentication: OAuth 2.0 (RFC 6749), API tokens, and refresh flows

• Communication: TLS 1.2 or higher for encryption in transit

• Data Format: JSON over RESTful HTTP, with ISO 20022 or ISO 8583 compatibility

• Consent Management: User-controlled, revocable, time-bound permissions with full auditability
  

This makes Vietnam’s API framework globally interoperable and highly secure. Banks must also provide developer portals, sandbox environments, API testing suites, and contractual terms (SLAs, data usage policies, and liability clauses) to participating third parties.

Combined, these technical and governance structures ensure that open banking won't compromise trust, even as it accelerates access.

Use Cases with Real Impact

The potential for open banking in Vietnam spans multiple verticals. Here are the most immediate opportunities:

1. Lending & Credit Scoring

Most Vietnamese borrowers are thin-file or credit-invisible. With real-time bank data—income flows, spending behavior, and transaction categorization—fintechs and banks can develop richer, more accurate credit models. This unlocks access to affordable loans for underserved populations.

2. Embedded Payments

Open APIs allow users to authorize payments directly from their bank accounts. This reduces friction, eliminates the need for cards or cash, and lowers transaction costs. Paired with QR-based instant payment rails (like VietQR), it could drive Pay-by-Bank adoption in e-commerce, utility bills, and gig economy apps.

3. Account Aggregation

Personal finance apps can unify bank account views across institutions. This enables users to track balances, analyze spending, and set savings goals—all from one interface. It’s especially helpful for Vietnam’s growing middle class, who often bank across multiple providers.

4. eKYC & Identity Verification

Bank-verified data can streamline KYC for new fintech users. With open banking, onboarding for new accounts or insurance products can be instant and secure.

5. SME & Treasury Tools

Businesses can automate cashflow forecasting, payroll reconciliation, and invoice settlement by plugging into bank APIs. This opens new avenues for SaaS fintech products serving Vietnam’s large SME sector.

Ecosystem Readiness: Who’s Involved?

Major Vietnamese banks are already preparing their open API architecture. Early adopters include VPBank, VietinBank, and TPBank, who have invested in API gateways, internal data orchestration, and open finance partnerships.

On the fintech side, players like Brankas, SAVIS, and Konsentus are offering API infrastructure, sandbox environments, and compliance-as-a-service tools. API aggregators such as FinOS and Fvndit are also preparing to connect dozens of third-party apps through secure integrations.

Digital wallets and super apps—like MoMo, ZaloPay, and ShopeePay—are closely watching these developments. With access to bank data, they can personalize offers, enhance wallet top-ups, and launch lending or investment features directly within their platforms.

Vietnam’s vibrant developer community is another advantage. With SBV mandating that banks host developer portals and testing tools, local tech startups are poised to build innovative consumer-facing tools atop this API layer.

Infrastructure Strengths & Challenges

Vietnam has laid strong foundations:

• High mobile penetration (>150% SIM connections per capita)

• Over 70% internet penetration

• Instant payment rails already deployed

• Government support for digital transformation through programs like National Digital Transformation Roadmap 2025
  

However, challenges persist:

• Legacy core banking systems could slow down API integration

• Data literacy and trust are still low among rural users

• Operational readiness varies widely across banks

• No formal consent dashboard yet for customers to manage API permissions across providers

SBV will need to work closely with the banking industry to manage this transition—not just technically, but culturally.

Fintech Sandbox: A Crucial Innovation Lab

The sandbox launched via Decree 94 gives banks and fintechs a place to experiment. It’s not just about regulatory breathing room—it’s a strategic step toward market-driven regulation. Use cases being prioritized include:

• Real-time SME lending platforms

• Identity-as-a-service based on eKYC and bank account verification

• Recurring bill payment APIs

• Cross-border payment trials with ASEAN QR interoperability

Approved players must follow strict guidelines: minimum capital, consumer protection policies, regular impact reporting, and exit strategies. SBV retains authority to intervene or terminate trials if risk thresholds are crossed.

This sandbox is a model that could influence ASEAN neighbors looking to build safe but flexible open finance environments.

Future Outlook: Vietnam’s Role in ASEAN

Vietnam’s approach to open banking reflects a smart blend of global standards and local adaptation. It’s learning from the EU’s PSD2, Australia’s CDR, and Singapore’s PayNow+FAST frameworks—but tailoring its system to support financial inclusion, SME growth, and digital literacy.

If implementation stays on track, Vietnam could soon become a regional open finance leader, especially as ASEAN explores QR code payment integration, digital identity systems, and real-time remittance corridors.

Looking ahead:

• We’ll likely see API monetization models emerge—subscription fees, tiered data access, or outcome-based pricing (e.g., per loan decision).

• Privacy dashboards will become necessary for users to manage app access and consent.

• Insurance, wealthtech, and health-fintech use cases will emerge as new datasets are opened.

• Banks will likely partner with fintechs to deliver white-labeled services or embedded finance APIs into B2B platforms.
  

Final Thoughts

Vietnam’s open banking journey is well underway—and it’s no longer just theory. With clear regulations, sandbox testing, and a rapidly maturing ecosystem, the country is turning potential into practice.

This is not just about APIs. It’s about creating a more inclusive, competitive, and innovative financial system. One where individuals and small businesses can access better services, on better terms, through better technology.

As deadlines approach and the sandbox kicks off, 2025 is shaping up to be a defining year for Vietnamese fintech. The opportunity is massive—and for those building infrastructure or launching apps, now is the time to lead.

Vietnam isn’t following the world’s open banking playbook. It’s writing its own chapter—and it may just become a regional model for how to do it right.