Main Points :
- Vietnam launched a five-year pilot program for regulated onshore digital-asset trading in September 2025 under Resolution No. 05/2025, aiming to bring crypto activity within the formal financial system.
- Though the pilot caps participation at just five licensed crypto exchanges, no companies have applied as of October 2025.
- Ultra-high capital requirements (≈ 10 trillion dong, ~US$379 million), prohibitions on stablecoins and tokenized securities, complex licensing, and ownership restrictions deter potential applicants.
- The Vietnamese government hopes to issue the first license by 2026 and is fast-tracking procedures, but success depends on how many firms can meet stringent requirements.
- The standoff underscores the tension between encouraging innovation and enforcing rigorous oversight, and it offers lessons and caveats for other jurisdictions planning regulated crypto frameworks.
1. Introduction of Vietnam’s Digital Asset Pilot (Resolution 05/2025)
On September 9, 2025, Vietnam’s government officially enacted Resolution No. 05/2025/NQ-CP, launching a five-year pilot program (2025–2030) to integrate digital assets into Vietnam’s formal financial infrastructure. This marks a dramatic shift from the prior de facto laissez-faire or offshore–dominated crypto activity toward a regulated, onshore framework. The law on Digital Technology Industry, passed in June 2025, underpins this move by granting crypto assets legal recognition as property or rights under civil law.
The goals of the pilot include:
- shifting trading activity from offshore or informal channels into regulated Vietnamese entities
- establishing taxation, accounting, and compliance rules for crypto
- collecting feedback from early participants to shape final regulation
- coordinating among key agencies (Ministry of Finance, Ministry of Public Security, State Bank) to finalize licensing systems.
However, with the launch underway, no firm has yet submitted an application to participate in the pilot.
2. The Absence of Applicants: What’s Blocking Participation?
2.1. Capital Requirements and Financial Barriers
A central barrier is the minimum charter capital requirement for crypto asset service providers (CASPs): 10 trillion Vietnamese dong, which equates to roughly US$379 million (subject to exchange fluctuations). This requirement is unusually steep—comparable to capitalization thresholds for full-scale commercial banks—making it prohibitive for many fintech and crypto startups.
For comparison, neighboring jurisdictions like Singapore, Japan, or Hong Kong often impose capital demands in the range of a few million to tens of millions of dollars, not hundreds of millions. CBecause of this disparity, many potential entrants may see Vietnam as less attractive relative to more permissive regimes.
2.2. Prohibition of Stablecoins and Tokenized Securities
Another key constraint is that stablecoins (i.e. fiat-backed coins) and tokenized securities are explicitly banned in the pilot. Only crypto assets backed by real, non-securities, non-fiat assets are permitted, severely narrowing the token universe. This restriction excludes many of the most traded and capitalized asset types globally (e.g. USDT, USDC, tokenized bonds, tokenized equities), reducing the attractiveness of the Vietnamese pilot market for participants seeking to list or trade them.
2.3. Ownership, Issuance, and Transaction Rules
The pilot also mandates:
- All crypto transactions must occur in Vietnamese dong, not foreign currencies.
- Only Vietnamese companies may issue digital assets; foreign issuers are excluded.
- Foreign investors can only participate through licensed CASPs, not directly.
- Complex licensing, staffing, audit, accounting, and compliance requirements make the application process onerous.
These rules collectively raise the entry threshold, not merely in capital but also in structural and operational capacity, making fewer firms viable candidates.
2.4. Uncertainty, Risk Aversion, and Market Perception
Given the novelty of the regulatory regime, many firms appear hesitant to commit substantial capital before terms are confirmed. Deputy Finance Minister Nguyen Duc Chi confirmed that no formal applications had been submitted by October 2025. He also emphasized that the pilot will be limited to five participants maximum, further intensifying competition.
Experts suggest the lack of applicants reflects not a lack of interest but regulatory caution and apprehension about compliance ambiguity. Some argue the choice to cap licenses at five may concentrate power in large institutions, discouraging smaller or innovative entrants.
3. Vietnam Moves to Accelerate Licensing and Market Entry
Despite the stall, the government is pushing forward to catalyze the pilot’s launch.
3.1. Timeline and Licensing Plans
Vietnam aims to issue at least one license before 2026, assuming eligible firms emerge. According to Deputy Minister Chi, the schedule hinges on how effectively enterprises meet all conditions. The Ministry of Finance is working with the State Bank, Ministry of Public Security, and others to finalize tax, accounting, and compliance regulations.
3.2. Regulatory Framework and Safeguards
The licensing regime is being shaped to balance innovation and consumer protection:
- Requirements for anti-money laundering (AML) and counter-terrorist financing (CFT) compliance
- Reporting, audits, and financial statement obligations
- Caps on foreign ownership and operational control
- Transaction tax proposals (0.1 %) discussed in early drafts
- Mechanisms for stakeholder feedback and adjustment during the pilot period
These safeguards echo global regulatory trends toward institutional-grade controls.
3.3. Preparatory Activities by Domestic Firms
Some Vietnamese firms are positioning themselves for entry by expanding business lines, raising capital, or planning exchange infrastructure. For example, HVA Group has announced plans to launch DNEX, a digital asset exchange in Da Nang, with a proposed capital raise of 10,000 billion dong (~US$400 million). Vemanti Group is among the strategic partners in this effort. Such moves may form a domestic anchor builder for pilot participation and could become one of the first licensees if successful.
4. Implications for Crypto Entrepreneurs, Investors, and Blockchain Use Cases
4.1. Caution for would-be entrants
For firms eyeing expansion into Vietnam, this episode suggests extreme regulatory risk: even a formally announced pilot might fail to attract participants if conditions are too demanding. Any entrant must carefully model capital, legal, operational, and compliance capability before applying.
4.2. Institutional bias and innovation tradeoff
High barriers and selective licensing can favor existing large financial players over nimble fintechs or decentralized protocols. This may slow feature innovation or limit alternative token models. Some critics argue this approach leans more toward controlling than enabling growth.
4.3. Onshore vs Offshore market dynamics
Much of Vietnam’s crypto trading—estimated at over US$100 billion per year—is already conducted offshore on platforms such as Binance, Bybit, OKX, etc. The pilot’s success—and its ability to lure activity back onshore—depends on whether licensed domestic platforms can compete in liquidity, fees, token variety, and user experience.
4.4. Lessons for other jurisdictions
Vietnam’s experiment will be closely watched elsewhere. It reveals that bold regulatory ambitions must balance realism in barrier setting. Other emerging markets may glean lessons about capital thresholds, phased rollouts, and the role of pilot/sandbox regimes in attracting participation.
4.5. Use case impact and blockchain strategies
Because stablecoins and tokenized securities are forbidden in the pilot, the types of blockchain use cases allowed are limited. DeFi, yield farming, tokenized bonds, or tokenized equity offerings may have to wait beyond the pilot phase. Instead, blockchain applications tied to real asset backing (e.g. commodities, real estate, supply chain) may be more viable initially under Vietnam’s regime. Entrepreneurs aiming for Vietnam should align their token models accordingly.
5. Summary & Outlook
Vietnam’s five-year crypto pilot represents a landmark attempt to bring digital assets from the shadows into regulated, tax-collecting, onshore channels. But as of late 2025, the program has stalled: no companies have yet applied, largely because capital demands, narrow product restrictions, and licensing uncertainty raise the bar too high. The government remains optimistic about issuing its first license before 2026 and is expediting regulation. But whether it can attract credible participants remains an open question.
For crypto innovators, this case is a vivid caution: regulation without practical calibrations may choke the market before it even begins. At the same time, Vietnam’s approach underscores a global trend: states are demanding responsible, institutional-grade frameworks for digital assets. For those seeking new crypto frontiers, the lesson is clear — understand the regulatory rigor as much as the market potential.
