Navigating Vietnam’s Fintech Future: Regulation, Foreign Investment & Banking Strategy

IKIGAI’s expansion reflects a strategic bet on Vietnam as a rapidly developing hub for cross-border finance, fintech, and talent mobility. By locating six strategic pillars—investment banking; fintech/digital banking; deep-tech; real estate and hospitality; agriculture and trade; and Japan-Vietnam talent flows—in Ho Chi Minh City, IKIGAI is anticipating regional growth in demand for financial services, digital transformation, and trade linkages. The choice of Vietnam is supported by recent reforms aimed at modernizing the regulatory and innovation environment.

Vietnam’s adoption of Decree 94/2025/ND-CP establishes a defined regulatory pathway for fintech and banking innovation, enabling foreign bank branches and fintechs to pilot solutions in areas like credit scoring, open APIs, and peer-to-peer (P2P) lending under supervision [2][3]. This gives IKIGAI a legal framework for engaging in fintech and digital banking with less regulatory ambiguity. The government’s push toward establishing international financial centres (IFCs) with more liberalized foreign exchange, capital market development, and simplified administrative and tax regimes further enhances this backdrop [5].

Nonetheless, there are constraints. P2P lending under Decree 94 requires Vietnamese ownership and Vietnamese nationals in the key management roles; foreign entities cannot independently operate P2P platforms [2]. Foreign ownership in Vietnamese banks remains capped at 30% under normal circumstances, rising to 49% only under special restructuring cases [4][6]. Hence, IKIGAI’s investment banking efforts or fintech operations needing banking licenses or operations tied to P2P may be structurally limited. Additionally, obtaining required authorizations, meeting local capital and cybersecurity requirements, and conforming to data localization and operational oversight are substantial operational considerations [2][4].

Strategic implications for IKIGAI include both opportunities and risk mitigation paths:

• Opportunity to ride legal momentum: With Decree 94 in force and IFC status in progress, IKIGAI can move quickly to launch fintech pilots, investment banking operations, and recruit local talent under favorable conditions.
• Need for partnerships: Because of ownership restrictions especially in P2P or banking entities, IKIGAI may need joint ventures or strategic local partners to operate fully in some sectors.
• Regulatory compliance burden: Compliance with licensing, data localization, sandbox limits, AML/CFT, cybersecurity will be costly and resource-intensive; errors may result in revocation, fines, or limitations.
• Open questions: Will IKIGAI seek full banking license or settle for digital banking under limited scopes? How will it structure its investment banking deals under Vietnam’s foreign ownership caps? What is their capital base, funding sources, and competitive strategy vs. incumbents?