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 Science & Technology implements Law 71/2025. AML/CFT supervision sits jointly across MoF and SBV.
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.
National Assembly Resolution 222/2025/QH15 — IFC
Passed 27 June 2025. The IFC operates a “one centre, two destinations” model:
- Ho Chi Minh City — fintech, banking sandbox.
- Da Nang — digital assets, crypto, advanced payment systems sandbox. Primary venue for crypto CASPs.
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 |
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.