Key Highlights ：
- Vietnam launches a five-year regulated pilot for cryptocurrency trading, effective immediately.
- Only Vietnamese-registered enterprises (LLCs or joint-stock companies) may participate; foreign ownership capped at 49%.
- Crypto assets must be backed by real, physical assets—issuance based on fiat currencies or securities is banned.
- Providers need at least VND 10 trillion (~$379 million), with ≥65 % from institutional investors.
- All issuance, trading, and payments must be conducted in Vietnamese dong.
- A six-month transition follows the first license issuance; thereafter, trading on unlicensed platforms by locals becomes illegal.
- Vietnam will legally recognize digital assets from January 2026 under a new law.
- Sandboxes earmarked for Da Nang and Ho Chi Minh City to boost innovation and build international financial hubs.
- Partnership between South Korea’s Dunamu (Upbit) and Military Bank to support a domestic exchange.
- Vietnam ranks among the world’s top countries in crypto adoption, with ~17 million holders and over $100 billion in digital assets.
Introduction: A Structured Leap into Crypto Regulation
Vietnam has officially embarked on a five-year pilot program to regulate cryptocurrency trading, marking a dramatic shift from its previously grey-market posture. As of September 9, 2025, Deputy Prime Minister Ho Duc Phoc signed a resolution that placed stringent requirements on the issuance, trading, and infrastructure of digital assets. This initiative aims to harness the country’s mature crypto ecosystem—ranked among the top globally in adoption—while introducing legal clarity and investor protection.
1. Domestic Control and Ownership Limits
Only Vietnamese enterprises—structured as LLCs or joint-stock companies—are permitted to launch crypto platforms and issue tokens. Foreign investors may participate, but their ownership is strictly capped at 49%. This ensures national oversight and prevents foreign dominance over the burgeoning digital asset market.
2. Capital and Institutional Requirements
Providers must bring a minimum of VND 10 trillion (≈ $379 million) in capital. At least 65% must come from institutional investors—such as banks, securities companies, fund managers, insurers, or tech enterprises—with at least two such institutions represented. This high bar filters for well-capitalized, reputable participants capable of maintaining financial and operational integrity.
3. Asset Backing and Currency Restrictions
Crypto assets under this pilot must be backed exclusively by “real, physical assets.” Issuance based on fiat currencies or securities is explicitly forbidden. Additionally, all issuance, trading, and payments must be conducted in Vietnamese dong, reinforcing monetary sovereignty and reducing exchange-rate risk.
4. Transition Period and Enforcement
After the first license is issued, a six-month transition window allows entities to migrate toward compliance. Once this period passes, trading on unlicensed platforms by Vietnamese users becomes illegal—though specific penalties have not yet been detailed.
5. Legal Recognition in 2026
This pilot sets the stage for full legal recognition of digital assets. Vietnam’s parliament passed a law in June for formal acknowledgment, which will take effect in January 2026. In parallel, blockchain and crypto are now among 11 priority technologies targeted by the government for driving double-digit economic growth.
6. Sandbox Zones and International Financial Hubs
Vietnam plans to establish crypto sandboxes in Da Nang and Ho Chi Minh City to foster innovation and test integration with traditional finance. A preceding sandbox project—Basal Pay in Da Nang—already demonstrates how blockchain can empower regulated crypto-fiat conversions with FATF Travel Rule compliance, cost reduction (~30%), and transparent record-keeping.
7. Strategic Partnerships for Infrastructure
Military Bank, a state-controlled bank under Vietnam’s Ministry of National Defense, has partnered with Dunamu (operator of Upbit) to develop a domestic crypto trading platform using Upbit’s technology. This cooperation reflects the government’s intent to blend global expertise with domestic control.
8. A Thriving Adoption Landscape
Despite the lack of legal frameworks, Vietnam’s crypto market has flourished. The country ranks fifth globally in crypto adoption, with approximately 17 million holders and over $100 billion in digital assets. This context underscores the urgency and potential upside of formal regulation.
Graph/Figure Suggestion
Description: A flowchart showing the regulated crypto ecosystem: Vietnamese enterprises → licensing → capital requirements (VND 10 trillion, 65% institutional) → asset-backed tokens → sandbox zones (Da Nang, HCMC) → foreign investors access only through CASPs → Jan 2026 legal recognition.
Conclusion: Regulated Innovation or Over-Control?
Vietnam’s five-year crypto pilot represents a bold and structured step toward legitimizing its vast, yet informal, digital asset ecosystem. By combining stringent requirements, domestic ownership mandates, and phased enforcement, the government aims to curb risks while preserving growth potential. The emphasis on real-asset backing, sandbox zones, and high capital thresholds suggests a national strategy rooted in stability over disruption.
For practitioners and investors seeking new crypto frontiers, Vietnam offers a unique case study—its regulated environment could foster robust, institution-backed innovation, though smaller agile players may find entry too costly. As the country transitions from experimentation to full legal recognition in 2026, its controlled approach could serve as a template for other emerging markets balancing crypto adoption with regulatory prudence.
