Main Points：
- Vietnam is moving to regulate and integrate its large crypto market (~US$100 billion annually, ~17 million users) into its financial system.
- A landmark law (Law on Digital Technology Industry) passed in mid-2025 will formally recognize digital assets, classify them as property, and demand compliant infrastructure (AML, cybersecurity).
- The government has launched a national blockchain platform, NDAChain, to underpin digital identity, issuance and trading of tokenized real-world assets, and interconnect exchanges with the banking & payment system.
- A five-year pilot (starting late 2025) will require exchanges to be licensed, trade in Vietnamese đồng, meet high capital requirements (e.g. ≈ VND 10 trillion ≈ US$380-400 million), cap foreign ownership, and enforce stricter oversight.
- Taxation policy is under development; while awaiting specific crypto tax law, digital asset transactions will temporarily be treated like securities; proposals for low transaction tax (e.g. 0.1%) could bring sizeable revenue.
- For investors, institutions, and practitioners, early entrants (licensed exchanges, tokenized RWA platforms) may have advantage; risk includes regulatory uncertainty, compliance burden, and possible sanctions for unlicensed dealings.
Background: A Huge Offshore Market and Domestic Gaps
Vietnam, despite strict past restrictions on cryptocurrency payments and limited legal clarity regarding crypto assets, has built one of the world’s highest rates of adoption. As of 2025, some 17 million Vietnamese are engaged in trading digital assets, mostly via foreign exchanges like Binance and Bybit, and annual transaction volumes are estimated to exceed US$100 billion.
Yet this activity has largely escaped domestic regulation, tax collection, or formal integration with the banking/payment system. For many years, the State Bank of Vietnam banned cryptocurrency as a payment method, and existing legal frameworks did not clearly define property rights, dispute resolution, and obligations for operators.
Landmark Legal Recognition: The Law on Digital Technology Industry
In June 2025, the Vietnamese National Assembly passed the Law on Digital Technology Industry, which will take effect January 1, 2026. This law officially recognizes digital assets (both “virtual assets” and “encrypted or crypto assets”), incorporates them under property law, and gives the government power to define oversight, classification, issuance, transfer, cybersecurity, and anti-money laundering requirements.
Some key aspects:
- Digital assets are now formally property under Vietnam’s civil code, so rights of ownership, transfer, inheritance, dispute resolution are legally supported.
- Securities and CBDCs (central bank digital currencies) are explicitly excluded from the crypto-asset definitions under this law.
- The law mandates standard regulatory guardrails: AML/CFT compliance, cybersecurity, data protection.
NDAChain: Building the National Blockchain Backbone
To support the digital asset regime, Vietnam has launched a government-backed blockchain platform named NDAChain. This platform is intended not only for crypto trading but also for digital identity management, tokenization of real-world assets (RWA), product traceability, secure e-government services, and integrating with banking infrastructure.
Details of NDAChain include:
- It is a permissioned / hybrid blockchain with governance involving public institutions and select private companies, intended to ensure oversight, efficient performance, and regulatory compliance.
- It supports or will support components such as decentralized identity (DID), identity verification tied to national ID, traceability of product supply chains, issuance of tokenized assets (bonds, invoices, carbon credits etc.).
The Pilot Program: Licensing, Capital, Dong Trading & Controls
With the legal foundation in place, Vietnam is rolling out a five-year pilot program for regulated crypto market operations, via Resolution 05/2025/NQ-CP. The pilot aims to move much of what is now offshore and informal into regulated onshore channels.
Requirements include:
- Exchanges or service providers must obtain domestic licenses, connect directly to banking/electronic payments, and offer trading denominated in Vietnamese đồng starting January 1, 2026.
- A high minimum charter/capital requirement: VND 10 trillion (~US$380-400 million) to meet technological, security, management and infrastructure standards.
- A cap on foreign ownership of licensed service providers: up to 49% foreign participation.
- Crypto assets issued must be backed by real underlying assets; unlicensed platforms and transactions will be penalized. Domestic investors must go through licensed providers for their crypto transactions after a grace period.
Taxation and Interim Measures
While the regulatory structure is now clearer, tax law specific to crypto is still under formation. Some of the current or proposed arrangements:
- Under Resolution 05, until specific crypto tax regulations are issued, crypto transactions will temporarily be treated like securities for tax purposes.
- Proposals suggest a transaction tax of 0.1% on trading could yield over US$800 million per year in revenue.
- Authorities are considering rules for taxing gains, fees, staking/mining (if allowed) and possibly VAT on services, though specifics remain to be defined.
Implications for Investors, Institutions, and Practitioners
For people looking for new crypto assets, platforms, or blockchain use-cases in Vietnam (or with exposure to Vietnam), here are the key implications:
- First-mover advantage: Entities that secure licensing, build compliant tech stack, and tie into NDAChain early may capture market share as domestic trading shifts onshore.
- Risk & compliance burden: High capital and operational requirements; penalties for unlicensed operations; need to implement AML/KYC, cybersecurity, data protection.
- Opportunity in real-world asset tokenization: Because Vietnam explicitly aims to tokenize real assets (bonds, invoices, carbon credits, etc.) via NDAChain, platforms built for this could be especially favored.
- Currency risk / fiat integration: Since trading will be in VND, participants will need to manage FX risk; integration with banking/payment infrastructure becomes crucial.
- Regulatory uncertainty remains: Specific regulations (tax, enforcement, permitted vs non-permitted assets, mining, stablecoins) are still being drafted; policy changes may occur.
Recent Developments & Related Moves
Since the initial announcement and passage of laws, further developments as of late 2025 include:
- Partnerships being formed for institutional infrastructure: for example, a joint venture between Korean custodian BDACS and Vietnamese IDGX to build custody, exchange, and digital asset system infrastructure under Vietnam’s sandbox framework.
- Continued media reporting of Vietnam’s government pushing for the regulation to capture offshore trading volumes (US$100 billion+) and enforce the licensing regime.
- Moves to ensure that domestic investors can no longer conduct transactions with unlicensed platforms after a grace period; stricter oversight is being emphasized.
Conclusion: Vietnam’s Crypto Turning Point
Vietnam is clearly entering a critical phase of transformation in its digital asset regime. What had been a massive, loosely regulated offshore crypto market is being called into domestic regulatory view. With legal recognition of digital assets, a national blockchain backbone (NDAChain), a licensing-and capital-rich pilot program, plus emerging taxation plans, the government is aiming to integrate crypto into its financial system — both to capture tax revenue and reduce systemic risks.
For creators, developers, institutional investors, and platforms, the message is: act now if possible — but ensure compliance. The opportunity is large, particularly for real-world asset tokenization and platform infrastructure, but so is the risk of being shut out or penalized if unlicensed or noncompliant. As always in crypto regulation, much depends on how the detailed rules will be written and enforced in practice.
