As of: 17 September 2026 Legal state: Resolution 222 provides for a financial sandbox: testing new financial models and technologies within a defined scope and timeframe, under the Executive body’s special supervision.[1] Authority state: Decree 323 gives the Executive Agencies in the cities power to promulgate sandbox rules, mechanisms and policies, and to license and manage technologies, products, services and business models not yet regulated by law for a maximum duration of five years.[2] Operating evidence: The current operator page describes sandbox access and sandbox models, while the Da Nang city report describes licensed city testing by Basal Pay and MIMO. The sources reviewed here do not identify a public IFC Executive Agency instrument naming a product, scope, supervising authority, conditions and term for a concrete sandbox approval. This is a limit of this review, not proof that no such instrument exists.[4][6]
Correction, dated 18 September 2026
The first version treated the word “sandbox” as if it settled a foreign fintech’s entry route into Da Nang. This revision corrects that overstatement. A legal framework, a city-level test and a product-specific IFC approval are different questions.
The framework exists.[1]
None of those labels, on its own, identifies a product approval.[1][5][6]
For a foreign fintech, the legal route, the operating authority and the evidence that a named product has actually been admitted are separate things.[1][2][4]
What the framework actually creates
Resolution 222 defines a financial sandbox as a mechanism for testing new financial models and technologies in the International Financial Center within a defined scope and timeframe, under the special supervision of the Executive body.[1] Article 24 says the Executive body shall provide for the sandbox and temporarily apply it to technologies, products, services and business models not yet regulated by law.[1]
Article 24 also describes the mechanism’s boundaries. Participants may bypass certain standards, technical regulations, business conditions and licensing procedures that are not suitable for the new characteristics of the model being tested. The exception is not a general waiver. The text ties the treatment to the proposed model and the experimentation procedure. It also gives a conditional protection from administrative, disciplinary and civil liability to the State for damage caused by objective reasons during the experiment, while keeping responsibility for damage to other organisations and individuals.[1]
Decree 323 places Da Nang inside one unified IFC operating at two locations. Its Article 3.4(b) gives Da Nang a development orientation around innovation, digital technology, sustainable finance, controlled testing of new financial models, digital assets, digital payments and specialised platforms. An orientation tells you what the city is being built to develop. It is not an operating licence or an admission decision for a particular product.[2]
Who can make the sandbox operational
Decree 323 Article 10.4(g) assigns the city Executive Agencies authority to promulgate sandbox regulations, mechanisms and policies and to license and manage unregulated technologies, products, services and business models for a maximum duration not exceeding five years.[2] The five years is a ceiling in the authority granted by the Decree.[2] It is not a standard term granted to every participant.[2]
The Executive Council’s Operating Regulation, Decision 05, took effect on signing and applies uniformly across the IFC.[4] Its Article 16 gives the city Executive Agencies up to six months from the Regulation’s effective date to coordinate with ministries and build and jointly issue controlled-testing rules, mechanisms and policies, while licensing and managing unregulated models for no more than five years.[4] A power to build or administer a mechanism is still different from a published decision admitting a named product to it.[4]
The current VIFC-DN operator page advertises access to regulatory sandboxes, sandbox models for digital currencies and stablecoins, and sandbox testing for startup fintech solutions.[5] That is evidence of the operator’s stated capability and positioning. It is not, by itself, the product-level approval instrument a prospective participant needs.[4][5]
Membership, licence and sandbox are different doors
An entity can face several separate questions:
| Question | What it establishes | What it does not establish |
|---|---|---|
| Membership registration or recognition | That the entity has been admitted through the applicable IFC membership route | That a regulated or unregulated product has sandbox approval |
| Sector-specific licence | That the relevant regulator has granted the operating permission for the licensed activity | That every other product or business model may operate |
| Sandbox approval | That a named product, service or model may be tested within defined boundaries | General market access, permanent authorisation or approval of a different activity |
Resolution 222 creates separate membership and licensing routes for financial institutions, securities organisations and insurers. Decree 324 says a Member must maintain its head office in the IFC and must obtain an operating licence or certificate of eligibility before conducting a conditional business line. Membership can therefore be part of an operating route without becoming a substitute for the route that governs the activity.[1][3] For finance and banking, Decision 05’s Annex I says the establishment-and-operation licence also serves as the membership-registration certificate. That dual function still does not identify a product-specific sandbox approval.[4]
The Regulation adds a published membership procedure and general evidence categories, not a named-product sandbox approval. Its Annex I describes direct, postal and system filing; a completeness check within two working days from receipt; registration-certificate issuance within seven days after a complete and valid dossier; and recognition-certificate issuance within five working days from receipt of a complete recognition dossier. Decree 324 Article 4 states a seven-working-day registration clock and a five-working-day recognition clock.[3][4] I am not collapsing the two registration wordings into one generic public deadline. The controlling Vietnamese texts and the filing route should be checked for the specific applicant.[3][4]
Its Annex II also identifies general membership evidence categories, including legal status, ownership and beneficial ownership, head office, financial capacity, fit-and-proper material, and activity fit with the IFC’s development orientation. Those criteria help explain a membership filing. They do not predict sandbox acceptance.[1][4]
City-level pilots are not automatically IFC pilots
A VietnamPlus report dated 27 August 2025 described Basal Pay as a Da Nang city controlled-fintech-sandbox project approved by the city People’s Committee. It also described a 36-month testing roadmap under city authorities. That report predates the December 2025 IFC decrees and the January 2026 IFC opening.[7]
The Da Nang city government reported on 28 February 2026 that Basal Pay and MIMO had been licensed to support digital-asset-to-fiat conversion at three specified city testing locations. It said users had to attend the licensed areas to make conversions, with digital assets usable for services within permitted limits.[6] The same report says MIMO had 11,712 registered users by the end of February 2026, including 8,295 verified accounts and 6,301 users who had completed eKYC.[6] Those are reported city-activity figures from that date, not a current live metric and not proof of IFC Executive Agency approval.[6]
The city report set 2030 targets of more than 100 registered and recognised IFC members and the launch of three sandbox programmes. Those targets are evidence of planned institutional development, not current participant counts or product approvals. They do not identify an IFC Executive Agency approval instrument, IFC scope, supervising terms or duration for either platform.[4][6]
A city report’s use of “licensed” is not enough to relabel a city-level pilot as an IFC sandbox approval.[4][6] The city report does not identify either platform as an IFC Member or as an IFC sandbox participant. The sources reviewed here do not establish a precedent for another applicant. This is a limit of the reviewed record, not a claim that no such status exists.[4][6][7]
What to ask before calling a route usable
Ask for the instrument, not just the label.[1][2] For the specific product and entity, request:[4]
- the membership, recognition or sector-specific route that applies;[1][3]
- the approval instrument and the authority that issued it;[4]
- the defined product scope, locations, user or transaction limits, duration and supervising body;[1][4]
- reporting, customer-protection and risk-management conditions;[1][4]
- the sector licence or regulator approval required before the test; and[3][4]
- the legal basis for any provision that is being bypassed or temporarily varied.[1][2]
A membership certificate, interest letter, company announcement or MoU can evidence membership, interest, intention or cooperation.[4][5] None alone identifies a product-level sandbox approval instrument, scope or term.[4]
What this does not decide
This post does not determine whether a named applicant, city pilot, IFC Member, payment product, stablecoin model or digital-asset activity is eligible, licensed, approved or operating lawfully.[1][2]
It records the legal framework, the Executive Agencies’ authority, current operator and city statements, and the gap between those facts and proof of a concrete product approval.[4][5][6]
Method
I re-fetched the official VIFC-DN legislation and business material, the Government Portal’s signed Decision 05 record and attachment, the Da Nang city report, and the cited VietnamPlus report on 17 September 2026.[1][2][3]
The VIFC-DN homepage supplies current operator context.[8]
As a bounded status check, I re-fetched the eight exact source URLs used in this post on 17 September 2026.
The cited legal, operator and city records did not identify a public IFC Executive Agency approval instrument for a named product.[4][5][6] The VietnamPlus report identifies a city-approved project instead.[7]
That result is limited to those cited records; it is not proof that no other instrument exists.[4][6][7]
The Vietnamese instruments are the legal authority.[1][2][4]
The Resolution 222 and decree wording used here comes from English reading copies hosted by VIFC-DN; the Vietnamese Resolution 222 original was not held in this corpus at review time.[1][2][3]
Decision 05 is the signed Vietnamese Government PDF; its scan has no usable text layer, so the Article 13, Article 16 and Annex references were checked against signed-page images and a local OCR reading record, with the PDF retained as authority.[4]
Operator, city and press statements are labelled as such.[5][6][7]
No named-platform IFC approval is inferred from these statements.[4][5][6]
Research and operational planning only. Not legal, tax, immigration, securities, investment, banking, payments, digital-asset, licensing, accounting, labor, or regulated financial advice. Describing a procedure is not advising on it. Formal decisions should be reviewed by qualified professionals in the relevant jurisdiction.
Sources
[1] Resolution 222/2025/QH15, official VIFC-DN English reading copy [2] Decree 323/2025/ND-CP, official VIFC-DN English reading copy [3] Decree 324/2025/ND-CP, official VIFC-DN English reading copy [4] Decision 05/QD-HDDHTTTC, signed Government PDF [5] VIFC-DN current business setup page [6] Da Nang city report, 28 February 2026 [7] VietnamPlus report, 27 August 2025 [8] VIFC-DN official homepage