Digital Asset Market Overview: Vietnam's Legal Framework and the Potential of Crypto Assets (Part 2)

From a Legal Gray Area to a Turning Point in Recognizing Crypto Assets

In 2017, as the global ICO boom gathered pace and brought with it risks that proved difficult to contain, Vietnam chose a cautious approach to establish safe boundaries for the market. Directive 02/CT-NHNN dated April 21, 2017, Official Letter 5747/NHNN-PC, and Decision 1255/QĐ-TTg dated August 21, 2017 all affirmed that Bitcoin and similar virtual currencies were not recognized as legal means of payment in Vietnam.

Rather than stopping at restricting use, however, the Government simultaneously tasked the Ministry of Justice and the State Bank of Vietnam with researching and gradually building a legal framework for a field that was still new and lacked any clear regulatory precedent.

By 2021, Vietnam's story had moved beyond simple risk prevention. Decision 942/QĐ-TTg marked a shift toward proactive research, tasking the State Bank of Vietnam with studying a pilot for blockchain-based cryptocurrency and working toward a central bank digital currency.

A year later, Decision 941/QĐ-TTg dated August 5, 2022 further extended the scope of regulation to cover anti-money laundering and counter-terrorism financing. This showed that crypto assets were no longer viewed simply as a new technological phenomenon but had become a field that needed to be regulated in connection with financial safety and international standards.

This years-long process of preparation laid the groundwork for a legal turning point in 2025 and 2026. On September 9, 2025, Resolution 05/2025/NQ-CP authorized a five-year pilot program for the crypto asset market, officially opening the way for organized trading activity under regulatory oversight for the first time.

Law No. 71/2025/QH15 then took effect on January 1, 2026, establishing the legal basis for recognizing cryptocurrencies such as BTC, ETH, and similar assets as legitimate digital assets. Less than three weeks later, Decision 96/QĐ-BTC dated January 20, 2026 moved the process from policy design into actual implementation, as the Ministry of Finance began building a licensing mechanism and the State Securities Commission started receiving applications from organizations seeking to enter the market.

These changes marked an important shift in how the crypto asset market operates in Vietnam. Before 2025, cryptocurrency was not recognized as a legal means of payment, and Vietnam had no licensing mechanism for domestic exchanges. Most trading activity therefore took place on international platforms, exposing investors to significant legal risk while capital flows and trading activity remained outside the direct oversight of domestic regulators.

Since 2026, though, the picture has begun to change as crypto assets are brought into a clearer legal framework and domestic trading activity is gradually organized under a licensing mechanism. Although cryptocurrency is still not recognized as a means of payment, opening a legal corridor for exchange and investment activity, together with requirements around customer identification, anti-money laundering, and counter-terrorism financing, has laid the foundation for the market to shift gradually from informal activity on international platforms toward a regulated and supervised domestic ecosystem.

The Roadmap Toward the First Exchange in the Third Quarter of 2026

Following Resolution 05/2025/NQ-CP dated September 9, 2025 and the entry into force of Law 71/2025/QH15 on January 1, 2026, the pace of building out Vietnam's crypto asset market has picked up considerably. The State Securities Commission began accepting license applications on January 20, 2026. By May 2026, five of the seven applications received preliminary approval, with the goal of bringing the first pilot exchange into operation during the third quarter of 2026.

While the journey from legal framework to actual implementation can take many countries several years, Vietnam is pushing this process through in roughly a single year. That pace reflects mounting pressure to bring crypto asset activity within a regulatory framework, given that a significant amount of domestic capital is still being traded on international platforms beyond the reach of domestic oversight.

For individual investors, the new legal framework is expected to raise the level of protection through KYC and AML requirements, segregation of client assets, and clear complaint mechanisms, thereby limiting the risks that come with informal trading. For businesses and financial institutions, the market opens up opportunities to develop new services such as running exchanges, custodying digital assets, and advising on issuance, while creating additional revenue as traditional lines of business such as credit and securities brokerage grow increasingly competitive. At the level of the broader economy, bringing trading activity within a domestic framework could help retain crypto asset capital, boost tax revenue, and support the emergence of a new layer of digital financial infrastructure.

Where Does Vietnam Stand on the ASEAN Crypto Asset Map?

Data from 2024 shows that demand for crypto assets in Vietnam had already taken shape well before a formal legal framework was put in place. Singapore leads ASEAN with 19.7% of its population using cryptocurrency, significantly ahead of Vietnam at 5.1% and the Philippines at 4.9%. Thailand follows at 3.7%, Malaysia at 3.4%, and Indonesia at 3%, while Cambodia stands at 2.7% and the remaining markets in the region average around 1.5%. At 5.1%, Vietnam ranks second in ASEAN according to PwC, even though it had no official legal framework recognizing crypto assets before 2026.

This suggests that the new legal framework is not creating an entirely new market, but is gradually bringing an already-established market, one that grew up on international platforms, into a licensed and supervised framework.

Source: Virtus Prosperity compilation

Vietnam's standing is also notable from a global perspective. According to Chainalysis's Global Crypto Adoption Index for 2024 to 2025, Vietnam has ranked among the world's top five countries for digital asset adoption for several years running. The sizable gap with Singapore points to substantial room for growth, but it also poses a bigger question. Vietnam needs to convert high grassroots adoption into formal capital flows and a genuinely competitive ecosystem. The legal framework established from 2026 onward is the foundation for that transition.

Completing the Regulatory Framework for the Crypto Asset Market

Vietnam's regulatory framework for crypto assets currently rests on five key legal documents:

Source: Virtus Prosperity compilation

Taken together, these policies show that the regulatory focus has shifted away from whether crypto assets should be recognized at all and toward more practical questions: who is permitted to provide services, what standards the market must operate under, and which agency holds supervisory responsibility.

Building on this foundation, the State Bank of Vietnam has proposed five policy pillars. The first is clarifying legal status and the implementation roadmap, including a sandbox for exchanges, custody wallets, and IDO activity. The second is building out licensing and risk control mechanisms, covering supervision, AML standards, and clearly assigning responsibility by token type. The third is refining tax policy, tracking capital flows, and studying a two-tier CBDC model. The fourth is strengthening interagency coordination and aligning with international legal standards. The fifth is raising awareness and enforcement capacity through education on virtual assets and training for the relevant authorities.

To translate this framework into practice, the role of each regulatory body has also been clearly defined. The Ministry of Finance serves as the lead agency, responsible for building the legal framework, completing the licensing mechanism, and coordinating with the State Securities Commission on both market oversight and tax policy. The State Securities Commission, meanwhile, is the body that directly receives and evaluates applications from virtual asset service providers, or VASPs, based on criteria covering financial capacity, technical infrastructure, operating processes, and expertise. Under the current framework, trading on licensed exchanges will be conducted in Vietnamese dong, with around 50 digital assets expected to be listed in the initial phase.

Regulatory responsibility is also divided by asset type. Security tokens fall under the State Securities Commission, utility tokens under the Ministry of Industry and Trade, and stablecoins under the State Bank of Vietnam, while VASPs must comply with anti-money laundering rules across the board. This approach shows that Vietnam is choosing to regulate based on the underlying nature of an asset rather than simply its label, an approach that echoes the direction taken by the CLARITY Act in the United States.

The Race for the New Market: Five Candidates for the Pilot Exchange Model

By mid-2026, seven applications had been submitted for the pilot program, five of which were selected by the Ministry of Finance to move into preliminary review, in coordination with the Ministry of Public Security and the State Bank of Vietnam. Under the plan, up to five organizations will be licensed and bring their exchanges into operation during the third quarter of 2026. These platforms are also expected to connect with international markets to ensure liquidity and strengthen competitiveness.

The list of candidates shows that Vietnam's crypto asset market is drawing in major financial and real estate ecosystems rather than just the technology startups that characterized the earlier phase. Notable names include Vietnam Digital Assets JSC, backed by Sun Group, and VIXEX, part of the VIX Securities ecosystem, both with charter capital of VND 1,000 billion. CAEX, part of the VPBank ecosystem, is targeting capital of VND 10,000 billion, while LPBank's LPEX has raised its capital from VND 6.8 billion to VND 360 billion. TCEX, part of the Techcombank ecosystem, has a smaller capital base but still draws participation from businesses within the same group.

The wide range in charter capital, from VND 3 billion to VND 10,000 billion, shows that Vietnam is still keeping a fairly flexible approach during the pilot phase. This is also one of the areas likely to be refined further as it is measured against international standards. The European Union's MiCA framework, for instance, sets minimum capital requirements ranging from EUR 50,000 to EUR 150,000 depending on the type of service, although its regulatory scope and licensing conditions are not entirely comparable to the model being rolled out in Vietnam.

The Next Pieces of the Digital Asset Ecosystem

Building new exchanges is only the first step in shaping Vietnam's crypto asset market. Alongside that effort, a number of sandbox programs are also underway to test new models and products before they are rolled out more broadly.

One notable direction is a pilot for issuing real-world asset (RWA) tokens to raise capital from foreign investors. Separately, Da Nang is running a sandbox for the Basal Pay stablecoin, developed by Alphatrue Solutions JSC, over a 36-month period from September 1, 2025 to August 31, 2028. The program requires mandatory eKYC, complies with the FATF Travel Rule, and sets a transaction threshold starting at USD 500. Choosing Da Nang as the pilot location also reflects an intent to develop the city into a fintech testing hub, tied to the broader goal of building an International Financial Center.

Alongside these sandbox programs, Vietnam is also studying a two-tier CBDC model, under which the State Bank of Vietnam would act as issuer while commercial banks handle distribution. These moves show that building out the market is not just about trading activity, but is gradually extending into payment infrastructure, capital raising, and other digital finance applications.

Tax and Anti-Money Laundering: Two Missing Pieces of the Market

As the crypto asset market is gradually brought within a regulatory framework, taxation has become one of the key factors in ensuring transparency and generating revenue for the state budget. International experience shows that most major economies, including the United States, Japan, Singapore, and Germany, have not created a separate tax category for crypto assets but have instead folded them into their existing tax systems.

In the United States, profits from crypto assets are subject to capital gains tax ranging from 10% to 37% for assets held under one year and from 0% to 20% for assets held for a year or more. Japan applies a progressive tax rate of 5% to 45%, while Singapore does not tax capital gains for individuals. Vietnam's approach, meanwhile, is oriented toward integrating crypto assets into the existing tax system with annual declarations. As transactions move onto licensed exchanges, the resulting data will also become more transparent, making tax administration and collection easier.

Alongside tax policy, anti-money laundering requirements are also being standardized in line with international practice. For virtual asset service providers, many countries require enhanced customer identification measures, transaction monitoring, and reporting of cross-border transactions worth USD 1,000 or more. This goes hand in hand with strengthening investor protection and dispute resolution mechanisms, both of which are areas Vietnam is expected to continue refining as it moves through the pilot phase.

Lessons from the Market

Before a clear regulatory framework existed, the market went through a string of costly episodes. Those losses became a major reason why the new licensing standards are being designed with tighter controls. In April 2018, iFan raised capital through tokens using a multi-level marketing model, causing an estimated VND 15,000 billion in losses. In July 2018, Sky Mining solicited investment in crypto mining rigs that had no real underlying value, resulting in losses of roughly VND 700 billion.

By August 2021, Wefinex and Antex emerged in the form of binary options and multi-level marketing platforms disguised as digital asset investments, each causing losses of more than VND 100 billion. In March 2022, the Ronin Bridge belonging to the Axie Infinity ecosystem, developed by Vietnam's Sky Mavis, was hacked, resulting in losses of more than USD 600 million. This was an incident of global scale but with a direct link to Vietnam's blockchain ecosystem.

These episodes have put pressure on the new regulatory framework to raise safety standards. For some categories, the proposed direction includes minimum charter capital of VND 10,000 billion, at least 35% of shares held by financial institutions, periodic disclosure obligations, and close oversight from regulators. Measured against the actual capital levels of today's pilot exchanges, which range from VND 3 billion to VND 1,000 billion, with only CAEX targeting VND 10,000 billion, these requirements point to a long-term benchmark the market may need to work its way toward over time.

Market Size Forecast: Two Scenarios Through 2030

By 2030, the size of Vietnam's crypto asset market could follow one of two different trajectories, depending on the direction of policy. According to PwC, the restrictive scenario assumes the market operates within a legal framework that is clear but strict, with tight rules on trading limits, anti-money laundering, tax obligations, and standards for virtual asset service providers. This approach prioritizes stability, capital flow control, and protection of the existing economic structure. In exchange, growth is projected at around 17.8% per year, and integration with the global market would likely proceed more slowly.

The base-case scenario, by contrast, assumes a more flexible regulatory framework that moves closer to international standards and encourages participation from global financial institutions. Under this approach, the market could grow by around 34.8% per year, drawing in larger capital inflows and creating momentum for the digital economy, though it would also face higher compliance risk and systemic risk.

Starting from a market size of roughly USD 18 billion in 2024, the market is forecast to reach around USD 48 billion by 2030 under the restrictive scenario and around USD 109 billion under the base-case scenario. The more than USD 60 billion gap between the two forecasts shows that policy does not only set the rules of the game, but can also directly shape the growth trajectory of the entire market.

These two scenarios are not necessarily an either-or choice that Vietnam has to make upfront. They may instead reflect different stages of the market's development. During the 2026-2028 pilot phase, a cautious approach centered on risk control, a limited number of licensed exchanges, and strict capital and AML standards will likely keep the market closer to the restrictive scenario. That is a reasonable choice for a brand-new market just beginning to operate.

If the pilot program proves effective and does not give rise to major risks, regulators will have more grounds to gradually ease entry conditions, expand the number of licensed organizations, and create room for deeper participation from international financial institutions. At that point, the growth trajectory could gradually shift toward the base-case scenario in the second half of the decade. The early signals from the third quarter of 2026, including trading volumes, the compliance record of licensed exchanges, and how policy responds to issues as they arise, will therefore be an important basis for investors and businesses to adjust their expectations over the medium and long term.

Crypto Assets in the Strategy for Developing the International Financial Center

Under Resolution 222/2025/QH15 dated June 27, 2025, the International Financial Center was formally established on December 19, 2025, with preliminary infrastructure investment of about USD 7 billion, equivalent to VND 172,000 billion. In the GFCI 38 ranking published by Z/Yen Partners and the China Development Institute, Ho Chi Minh City scored 664 points, up 10 points from the previous edition, placing it among the 15 financial centers projected to grow fastest over the next two to three years.

HCMC International Financial Center

Under this strategy, digital asset exchanges are planned for both Ho Chi Minh City and Da Nang, tied to broader plans for smart banking, green finance, and fintech. Ho Chi Minh City is positioned as the international financial hub, while Da Nang plays a supporting role, testing new models before they are scaled up.

Folding crypto assets into the International Financial Center strategy shows that the sector is no longer viewed as a standalone pilot program, but has become part of the country's broader plan for building financial infrastructure. This also gives grounds to expect that resources, institutions, and policy attention for the crypto asset market will continue to be prioritized through 2030.

Conclusion

Vietnam is entering the crypto asset market at a point when many international standards have already matured, from MiCA in the EU to the GENIUS Act and CLARITY Act in the United States. That gives it the advantage of a late mover, with the chance to draw on proven models and build a legal framework suited to domestic conditions. The issuance of Resolution 05/2025/NQ-CP and Law 71/2025/QH15 also marks an important turning point, moving the crypto asset market from a phase of informal growth into a clearly regulated and supervised framework.

Even so, the new legal framework is only a starting point. The market's success will depend on striking a balance between three goals: protecting investors, controlling risk, and encouraging innovation. If the pilot program is carried out transparently and effectively, Vietnam stands to gain not just the chance to bring crypto asset capital into a formal framework, but also the opportunity to build a digital asset market that becomes a new driver of its digital economy in the years ahead.