Overview
Vietnam's crypto regime moved from grey zone to controlled pilot in the second half of 2025. Three instruments shape the 2026 market: Law 71/2025/QH15 on the Digital Technology Industry (effective 1 January 2026), which legally recognises digital assets as a property category; Government Resolution 05/2025/NQ-CP (effective 9 September 2025), which establishes the 5-year crypto-asset market pilot under MoF licensing of CASPs; and National Assembly Resolution 222/2025/QH15 (passed 27 June 2025), which establishes the International Financial Centre (IFC) on a “one centre, two destinations” model with Da Nang as the primary venue for digital assets and crypto.
What this means in practice: a Vietnam crypto licence in 2026 is a CASP licence issued by the Ministry of Finance, with operations physically based in the IFC Da Nang sandbox, capital of VND 10,000 billion (about USD 400 million), and a 49% foreign ownership cap. The first cohort is expected to be small, around five licences.
Regulators
The Ministry of Finance is the licensing authority for the crypto-asset pilot. The State Bank of Vietnam retains the monetary and payments remit and continues to prohibit crypto as a means of payment. The State Securities Commission supervises tokenised securities within the IFC sandbox. The Ministry of Information & Communications / Ministry of Science & Technology implements Law 71/2025. AML/CFT supervision sits jointly across MoF and SBV. Primary legislation is published via the National Assembly portal; CASP applicants incorporate through the Vietnam Business Registration portal and register with the General Department of Taxation.
Law 71/2025/QH15. Law on the Digital Technology Industry
Passed 14 June 2025, effective 1 January 2026. The first Vietnamese statute to legally recognise digital assets (tài sản số) as a property category under the Civil Code 2015. Three sub-categories:
- Virtual assets (tài sản ảo), for exchange or investment purposes.
- Crypto assets (tài sản mã hoá), using cryptography or DLT.
- Other digital assets.
The law excludes securities, digital fiat and other financial assets covered by existing financial laws. It does not legalise crypto as a means of payment, payment use remains prohibited.
Government Resolution 05/2025/NQ-CP. Crypto Asset Market Pilot
Issued 9 September 2025, effective the same day, with a 5-year pilot period. Licensing body: Ministry of Finance. Licensed party: Crypto Asset Service Provider (CASP).
| Item | Value |
|---|---|
| Minimum charter capital | VND 10,000 billion (~USD 400 million) |
| Institutional ownership minimum | ≥ 65% collectively, with ≥ 35% held by at least two qualifying institutions |
| Foreign ownership cap | 49% |
The often-cited label “Resolution 05/2025/QH15” conflates two separate instruments. The National Assembly instrument is Resolution 222/2025/QH15 (the IFC Resolution). The crypto-pilot instrument is the Government's Resolution 05/2025/NQ-CP. Both apply.
Decision 96/QĐ-BTC, application window open
On 20 January 2026, the Ministry of Finance issued Decision No. 96/QĐ-BTC, the implementing decision that operationalises Resolution 05/2025/NQ-CP: it sets the dossier format, the intake workflow and the review windows for CASP applicants. Decision 96 is the practical trigger for applications, from 20 January 2026 onwards Vietnamese enterprises that meet the pilot criteria may formally submit to the MoF. The Decision works alongside Decision No. 36/2025/QĐ-TTg (effective 15 November 2025), which aligns registered business lines with the new Vietnamese economic-classification system so that CASP activity can be coded at the tax registry.
In practice, Decision 96 reframes a scheme that existed on paper since September 2025 into a live administrative counter. It does not relax the core capital, ownership or geographic settings of Resolution 05, it sequences them.
National Assembly Resolution 222/2025/QH15. IFC HCMC and Da Nang
Passed 27 June 2025. The IFC operates a “one centre, two destinations” model:
- IFC Ho Chi Minh City, fintech and banking sandbox. The HCMC leg focuses on regulated payments, open banking, insurance-tech and tokenised-deposit pilots. It is the natural home for IFC-resident banks that sit inside a CASP consortium but is not, under the current reading, the primary venue for the crypto-exchange licence itself.
- IFC Da Nang, digital assets, crypto and advanced payment systems sandbox. Da Nang is the primary venue for CASPs: the Ho Chi Minh City–Da Nang split is the regulatory reason a pilot CASP applicant establishes its operational base in Da Nang while its bank consortium members remain headquartered in HCMC or Hanoi. Final geographic allocation sits with the implementing decree to Resolution 222.
High-level checklist
- Vietnamese joint-stock company (công ty cổ phần) with operational base in IFC Da Nang.
- Charter capital VND 10,000 billion fully contributed and certified by a commercial bank.
- Institutional ownership floor: ≥ 65% by qualifying institutions, with ≥ 35% across at least two such institutions.
- Foreign ownership ≤ 49%.
- Fit-and-proper assessment of directors, senior officers and controlling shareholders.
- AML/CFT programme aligned with MoF and SBV joint supervision; FATF Travel-Rule alignment via IFC-specific circulars in preparation.
- Custody architecture, market-operations framework and consumer-protection rulebook aligned with the pilot conditions.
- Application to MoF and IFC review board; respond to clarification rounds.
- Post-licensing: pilot reporting, periodic supervisory inspections, IFC governance compliance.
Process and timeline
| Stage | Duration |
|---|---|
| Consortium formation (meet 65% institutional rule) | 3–6 months |
| IFC Da Nang entity setup and charter-capital certification | 3–4 months |
| Application drafting (AML, custody, technology, market ops) | 4–6 months |
| MoF + IFC review | 9–12 months (first cohort limited to ~5 licences) |
| Total | 18–24 months |
Pilot micro-deadlines under Decision 96/QĐ-BTC
Inside the 18–24 month envelope, Decision 96 imposes a tight administrative cadence. Once a dossier enters the MoF, the clock runs on statutory day-counts, not quarters. Applicants should pre-build the evidentiary file so that each window can be met without remediation.
| Administrative step | Statutory window |
|---|---|
| Initial MoF review of the dossier | 20 days |
| Supplemental dossier completion (applicant-side) | Up to 12 months |
| Formal appraisal and licence issuance | 30 days |
| Post-licensing public disclosure | 7 working days |
| Commencement of pilot operations after licence | 30 days |
The 12-month supplemental window is where most first-cohort applicants will spend their time: consortium certification, bank charter-capital letters, AML programme sign-off by an independent reviewer, technology audit and market-surveillance architecture all sit in that phase. Missing a day-count triggers either rejection or a restart of the dossier.
First cohort and offshore-exchange restrictions
Public reporting from early 2026 places the first cohort at around five licences, heavily weighted toward consortia anchored by commercial banks, large securities firms and diversified conglomerates, the same categories that Resolution 05/2025/NQ-CP recognises as “qualifying institutions” for the ≥65% institutional floor. In parallel, policy direction from Hanoi is to channel retail flow toward domestic licensed venues and to tighten access to offshore crypto-exchange services for Vietnam-resident users. This “local-first” policy posture is the strategic reason the pilot can sustain a VND 10,000 billion capital floor: the regulated market is intended to be the only market.
For a foreign operator, the implication is direct: unlicensed cross-border servicing of Vietnamese users is on a narrowing runway, and inbound market access effectively requires a seat inside the IFC Da Nang consortium rather than a pure offshore structure.
Taxation
- Corporate income tax: 20% standard. IFC-resident entities may access reduced CIT, 10% for up to 30 years per Resolution 222 incentive framework. Precise schedule pending the implementing decree.
- VAT: draft implementing rules under MoF, current indication is VAT-exempt on crypto-asset trading services within IFC, to be confirmed.
- Personal income tax on crypto gains: the legal status of crypto as property is clarified by Law 71/2025 but the rate and withholding mechanism are pending an MoF circular.
FAQ
Is crypto legal in Vietnam now?
Holding and trading are legally recognised through Law 71/2025 (effective 1 January 2026). Payment use remains prohibited. Licensed CASPs operate inside the IFC Da Nang sandbox.
What is the charter capital?
VND 10,000 billion (~USD 400 million), fully contributed and bank-certified. The first cohort is intended for around five licences.
Can a foreign exchange enter without a domestic partner?
No. The 65% institutional ownership floor with a ≥35% two-institution leg, combined with the 49% foreign cap, requires a domestic institutional consortium.
How does Vietnam compare with Indonesia?
Indonesia is also high-capital (IDR 100bn ≈ USD 6M) but is a national open regime. Vietnam is sandbox-only at much heavier capital (USD 400M) and tighter ownership rules.
How fast can the regime evolve?
Resolution 05/2025/NQ-CP runs as a 5-year pilot. Implementation circulars on AML/Travel Rule, tax and licensing process are being issued in waves through 2026.
What does Government Resolution 05/2025/NQ-CP permit?
Issued and effective 9 September 2025, it sets a 5-year pilot for the CASP licence awarded by the Ministry of Finance, covering crypto-asset trading, custody, brokerage and ancillary market infrastructure. Payment use of crypto remains prohibited under the legacy SBV position.
What are the entry criteria for IFC HCMC and Da Nang?
Under Resolution 222/2025/QH15, HCMC hosts the fintech and banking sandbox and Da Nang hosts digital assets, crypto and advanced payments, the primary venue for CASPs. Entry requires a Vietnamese JSC inside the IFC, VND 10,000 billion charter capital bank-certified, ≥65% institutional ownership (two-institution 35% leg) and foreign ownership ≤49%.
When does the pilot end?
Five years from 9 September 2025, so by September 2030. The Government then decides on the permanent regime, conversion to a standing licence class, recalibration of capital/ownership rules, or sandbox extension. MoF files quarterly reports during the pilot.
Who is the regulator. MoF, SBV or MIC?
MoF is the primary licensing authority for CASPs under Resolution 05/2025/NQ-CP. SBV co-supervises monetary, payment and AML matters and maintains the payment-use ban. SSC supervises tokenised securities inside the IFC. The Ministry of Science and Technology implements Law 71/2025/QH15.
What are the foreign-invested entity rules?
A CASP must be a Vietnamese JSC, not a branch of a foreign entity. Foreigners hold ≤49% of charter capital, behind a domestic institutional block of ≥65% with at least two qualifying institutions jointly at 35%. Directors, CEO and controlling shareholders are subject to MoF fit-and-proper review.
Can licensed CASPs access banking given the SBV crypto ban?
Yes, the SBV ban targets crypto as means of payment, not CASP corporate banking. Pilot CASPs hold fiat operating and charter-capital accounts with commercial banks, and the bank certifies the VND 10,000 billion paid-in capital. SBV-MoF joint circulars on client-money segregation are expected in 2026 Q2.
What AML obligations apply?
Joint SBV and MoF AML/CFT supervision aligned with Vietnam's AML Law and FATF Recommendation 15. A Travel Rule circular specific to the IFC is in preparation. Obligations include CDD, beneficial-ownership identification, sanctions screening, STR filing to SBV AMLD and a written AML programme filed at application.
How are corporate and personal income from digital assets taxed?
Standard CIT 20%; IFC-resident entities may access 10% CIT for up to 30 years under the Resolution 222 incentive framework, schedule pending the implementing decree. PIT on crypto gains is clarified in principle by Law 71/2025/QH15 (digital assets as property) but rate and withholding are pending an MoF circular. VAT on crypto-asset trading inside the IFC is indicated as exempt, to be confirmed.
How does the tokenisation framework distinguish utility from securities?
Law 71/2025/QH15 defines digital assets with three sub-classes: virtual assets, crypto assets and other digital assets. Securities, digital fiat and other financial assets remain under the Securities Law and SSC jurisdiction. Tokenised securities in the IFC sit with the SSC; utility and payment-adjacent tokens sit with MoF under the CASP pilot.
Is cross-border passporting available from the IFC?
No automatic passporting. A Vietnam CASP licence authorises services from the IFC but does not grant market access into other APAC jurisdictions. Cross-border offering is structured separately, typically via a Singapore, Hong Kong or Labuan entity, with the IFC entity serving Vietnam-resident and IFC-domiciled clients.
What is the sandbox sequence, consultation, application, pilot launch?
Pre-application consultation with MoF and the IFC authority; 3–6 months to assemble the ≥65% institutional block; 3–4 months to incorporate the IFC Da Nang JSC and certify charter capital; 4–6 months to draft the licence file (AML, custody, technology, market-ops); 9–12 months MoF and IFC review; conditional pilot launch with quarterly MoF reporting for the 5-year duration.
What is Decision 96/QĐ-BTC?
Decision No. 96/QĐ-BTC is the MoF implementing decision that operationalises Resolution 05/2025/NQ-CP. Effective 20 January 2026, it sets the dossier format, intake workflow and day-count review windows, 20-day initial review, up to 12 months for supplemental submissions, 30-day appraisal, 7-working-day disclosure, and 30 days to commence pilot operations after licence. It is the practical trigger opening the CASP application window.
Is the crypto licence issued in IFC HCMC or IFC Da Nang?
Under the “one centre, two destinations” model of Resolution 222/2025/QH15, IFC HCMC hosts fintech and banking; IFC Da Nang hosts digital assets, crypto and advanced payments, the primary venue for CASPs. A typical consortium has its CASP operational base in Da Nang while bank members remain headquartered in HCMC or Hanoi. Final geographic allocation rests with the implementing decree to Resolution 222.
Does Vietnam block offshore crypto exchanges?
Policy direction from early 2026 is to channel retail flow to domestic licensed venues and to restrict access to offshore crypto-exchange services for Vietnam-resident users. The expectation is a narrowing runway for unlicensed cross-border servicing. Foreign operators seeking Vietnam-resident users should plan for IFC Da Nang consortium entry rather than offshore-only structures.
Which Vietnamese institutions are applying in the first cohort?
Resolution 05 recognises five qualifying-institution categories, commercial banks, securities firms, fund managers, insurers and technology enterprises. Public reporting indicates the first cohort (around five licences) is dominated by consortia anchored by commercial banks and diversified conglomerates, reflecting both the VND 10,000 billion capital floor and the ≥65% institutional ownership rule that requires two qualifying institutions jointly at 35%.
What changes after the pilot, what are the risks?
Residual risks: (i) MoF circulars on fit-and-proper, tax and Travel Rule still being issued through 2026; (ii) the reported first-cohort cap of around five licences may tighten before award; (iii) potential recalibration of the VND 10,000 billion capital floor or 49% foreign cap at pilot end in 2030; (iv) final geographic allocation between HCMC and Da Nang pending the implementing decree to Resolution 222.