Vietnam’s Crypto Moment: Inside the Government’s First Real Move to Regulate Digital Asset Markets

For years, Vietnam’s relationship with crypto has been paradoxical.

On one hand, Vietnam consistently ranks among the top countries globally for crypto adoption, with millions of users trading digital assets daily. On the other hand, from a legal perspective, crypto has existed in a grey zone, neither fully legalised nor comprehensively regulated. Exchanges operated offshore. Users traded through foreign platforms. Regulators watched, studied, and waited.

That waiting period is now over.

In January 2026, Vietnam quietly but decisively crossed a regulatory Rubicon. With the issuance of Decision No. 96/QĐ-BTC by the Ministry of Finance, the country formally launched the pilot implementation of a regulated crypto-asset market, introducing a licensing framework for crypto-asset trading platforms for the very first time.

This is not a press release.
It is not a policy paper.
It is not a theoretical roadmap.

It is hard law, with procedures, capital thresholds, governance requirements, and enforcement mechanisms.

This article unpacks what this decision really means, legally, commercially, and strategically, and why it marks a turning point not only for Vietnam, but for how emerging markets may approach crypto regulation going forward.

1. From Silence to Structure: How Vietnam Got Here

To understand the significance of this move, one must first understand Vietnam’s regulatory philosophy.

Vietnamese regulators have historically favoured incremental control over rapid liberalisation. Financial innovation is not blocked outright, but it is rarely embraced without extensive testing. The preference is for state-supervised pilots, followed by gradual expansion.

Crypto, by its very nature, challenged this approach; Decentralised. Borderless. User-driven.

For years, the State Bank of Vietnam and the Ministry of Finance issued warnings rather than licences. Crypto was not recognised as legal tender. No formal regime existed for exchanges. Yet adoption exploded anyway.

Rather than rushing into regulation, the government chose observation. Task forces were created. Inter-ministerial working groups studied foreign models, including the EU, Singapore, Japan, and China. The result was Government Resolution No. 05/2025/NQ-CP, which authorised a pilot crypto-asset market.

Decision No. 96/QĐ-BTC is the operationalisation of that resolution.

This is where theory becomes practice.

2. What the Decision Actually Does

At its core, the Decision does one very specific thing:

It publishes three new administrative procedures governing the licensing, amendment, and revocation of crypto-asset trading market operators during Vietnam’s pilot phase.

These procedures fall under the regulatory authority of:

• The Ministry of Finance, and
• The State Securities Commission (SSC)

In other words, crypto exchanges are being regulated as market infrastructure, not as payment providers. This distinction matters a lot.

Vietnam has chosen to treat crypto-asset trading platforms more like securities exchanges or organised trading venues, rather than fintech payment companies. This choice shapes everything that follows.

3. The Pilot Philosophy: Why This Is Not a “Crypto Boom” Law

Before diving into the licensing mechanics, it is important to dispel a misconception.

This is not a liberal crypto-friendly law designed to attract hundreds of startups.

It is the opposite. The pilot framework is:

• Highly selective
• Capital-intensive
• Institution-focused
• Systemically conservative

Vietnam is not asking, “How do we let everyone in?”

It is asking, “How do we test crypto safely, with players we can control?”

This is why the requirements are deliberately high.

4. The Crown Jewel: The Crypto Market Operator Licence

The centrepiece of the Decision is the procedure titled: “Grant of licence to provide crypto-asset trading market organisation services.”

This is, in substance, a crypto exchange licence, but one that goes far beyond what most jurisdictions require.

4.1 Who Can Apply?

Only:

• Vietnamese-incorporated companies
• Established as either: (i) A limited liability company, or (ii) A joint stock company

There is no passporting, no offshore licensing recognition, and no fast-track for foreign exchanges.

If you want to operate, you must be onshore, Vietnamese, and fully visible to regulators.

4.2 The Capital Requirement That Changes Everything

The most striking requirement is capital.

Minimum paid-up charter capital: VND 10,000 billion

This is approximately USD 400 million.

To put this into perspective:

• This exceeds the capital requirements of many licensed crypto exchanges globally
• It immediately excludes startups, scale-ups, and most Web3-native firms

This is intentional.

Vietnam is signalling that crypto market infrastructure is:

• Systemically important
• Financially risky
• Not suitable for undercapitalised operators

4.3 Ownership Structure: Institutions First, Always

The ownership rules further reinforce this philosophy.

Key requirements include:

• At least 65% of the capital must be held by institutional shareholders
• At least 35% must be held by a minimum of two regulated institutions, such as:
  • Commercial banks
  • Securities firms
  • Fund management companies
  • Insurance companies
  • Large technology enterprises
• Foreign ownership is capped at 49%

In addition, each investor (individual or institution) may only invest in one licensed crypto-asset service provider

This prevents:

• Regulatory arbitrage
• Cross-ownership risks
• Market concentration through hidden structures

5. Governance, Personnel, and the Human Factor

Unlike jurisdictions that focus primarily on technology, Vietnam places enormous emphasis on people.

5.1 Senior Management

The rules require:

• A CEO with at least two years’ experience in regulated financial sectors
• A CTO with at least five years’ experience in financial or enterprise technology

This effectively rules out:

• Anonymous founders
• Pseudonymous teams
• Pure crypto-native leadership without traditional finance exposure

Vietnam wants executives who:

• Understand regulators
• Understand compliance
• Understand institutional risk

5.2 Staff Requirements

The platform must employ:

• At least 10 cybersecurity-qualified IT personnel
• At least 10 licensed securities professionals in operational roles

This is another clear signal:
Crypto is being fused into the existing capital markets ecosystem, not treated as a parallel universe.

6. The Compliance Engine: Processes, Policies, and Controls

Perhaps the most demanding aspect of the licence is the required internal framework. Applicants must submit detailed written procedures covering, among others:

• Risk management
• Information security
• Custody and client asset protection
• Trading and settlement
• Proprietary trading
• AML/CFT and counter-proliferation financing
• Information disclosure
• Internal controls
• Market surveillance
• Conflict of interest management
• Complaint handling and customer compensation

This mirrors  and in some areas exceeds, traditional exchange rulebooks.

Crypto platforms are no longer just matching engines. They are regulated financial institutions in all but name.

7. Technology and Cybersecurity: Level 4 or Nothing

Technology is not an afterthought. Vietnam requires the platform’s IT systems to meet Level 4 cybersecurity classification under national information security laws before going live. This involves:

• Government security assessments
• Approval by the Ministry of Public Security
• Ongoing monitoring obligations

This is among the highest cybersecurity thresholds applied to any crypto regime globally.

8. The Two-Stage Licensing Process: A Test of Commitment

The application process itself is revealing. It is not a single submission. Instead:

1. Applicants submit an initial dossier
2. The Ministry of Finance reviews it and, if satisfied, authorises the applicant to proceed
3. The applicant then has up to 12 months to submit the remaining documents
4. Only then does final licensing occur

This structure filters out:

• Speculative applicants
• Undercapitalised ventures
• “Paper exchanges”

Only firms with genuine long-term commitment will survive the process.

9. Licence Amendments and Revocation: Control Never Ends

The Decision also regulates:

• Licence amendments (name, address, capital, management)
• Licence revocation (voluntary or regulatory)

Amendments are processed quickly, but only with full disclosure and supporting documentation. Revocation can occur within five working days, underscoring the regulator’s ability to act decisively.

This is not a “licence once, forget forever” regime.

10. Why Vietnam Chose This Model (And Why It Matters)

Vietnam’s approach differs sharply from:

• The EU’s MiCA framework
• Dubai’s VARA regime
• Singapore’s PSA model

Instead of broad market access with tiered regulation, Vietnam opted for:

• Centralised control
• Limited participants
• Institution-led experimentation

This reduces:

• Retail harm
• Market manipulation
• Systemic contagion

But it also limits:

• Innovation
• Startup participation
• DeFi integration (at least for now)

Vietnam is not anti-crypto. It is anti-chaos.

11. What This Means for the Market

For Local Institutions

This is a once-in-a-generation opportunity to shape Vietnam’s crypto infrastructure from day one.

For Foreign Exchanges

Market entry will require:

• Local partnerships
• Minority positions
• Strategic patience

For Users

Expect:

• Fewer platforms
• Higher compliance
• Stronger protections
• Slower product innovation

12. The Bigger Picture: A Signal to Emerging Markets

Vietnam’s pilot may well become a template for other emerging economies:

• Large retail adoption
• Limited regulatory capacity
• Desire for state control

Rather than copying Western crypto regimes, Vietnam has created its own path.

13. A Quiet, Powerful Regulatory Shift

Decision No. 96/QĐ-BTC will not make headlines like ETF approvals or Bitcoin price surges. But from a legal and regulatory perspective, it is far more consequential. It marks the moment Vietnam moved from:

“Crypto exists” to “Crypto will exist, on our terms.”

For the global crypto industry, the message is clear:

The next phase of crypto adoption will not be driven by hype alone, but by law, institutions, and state-designed market structures. Vietnam has entered that phase, carefully, deliberately, and with its eyes wide open.

Disclaimer:

This article is for informational and educational purposes only and does not constitute legal advice. Regulatory frameworks evolve, and professional advice should be sought before making any business or investment decisions related to crypto-asset activities in Vietnam or any other jurisdiction.

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