Crypto and tokenized assets in Vietnam in 2026 stand at a turning point: for the first time recognized by statute as assets, while the Government pilots a 5-year market under tight controls. Yet this remains a forming market — there is no complete legal framework comparable to securities or banking.
This article outlines the current legal framework for digital assets and crypto in Vietnam as of October 2026: what the law already recognizes, what is still being piloted, and what investors must absolutely not do.
1. The turning point: digital assets recognized by statute for the first time
The Law on Digital Technology Industry (Law No. 71/2025/QH15, effective 1 January 2026) for the first time recognizes digital assets — including crypto assets — as assets under civil law. This is a major milestone: previously, crypto existed in a “grey zone” with no clear legal definition, leaving ownership protection and dispute resolution with almost no legal basis.
Recognition as “assets” opens the door to applying the general provisions of the Civil Code 2015 on ownership, transfer and protection of assets — although detailed rules for each digital-asset type are still being completed.
2. Five-year pilot of the crypto-asset market: Resolution 05/2025/NQ-CP
On 9 September 2025, the Government issued Resolution 05/2025/NQ-CP on piloting the crypto-asset market in Vietnam for 5 years, under strict control principles:
- Transactions in Vietnamese dong;
- Crypto assets may be offered and issued only to foreign investors (domestic investors may trade on the secondary market within the pilot framework);
- Crypto-asset service providers must have charter capital of at least VND 10,000 billion;
- A maximum of 5 organizations selected as service providers;
- The Ministry of Finance leads, coordinating with the Ministry of Public Security and the State Bank of Vietnam in selection and supervision.
On the roadmap: the Ministry of Finance published administrative procedures and has accepted licensing dossiers since 20 January 2026; by March 2026, of 7 dossiers received, 5 had entered the inter-agency consultation stage. As of October 2026, the pilot market remains in the review and licensing phase — no domestic crypto-asset exchange is officially operating yet.
3. Sanctions: Decree 284/2026/ND-CP
On 16 July 2026, the Government issued Decree 284/2026/ND-CP on administrative sanctions for crypto assets and the crypto-asset market, effective 1 September 2026, with maximum fines of VND 200 million for organizations and VND 100 million for individuals. Acts such as providing false information or failing to publish a prospectus may be fined with additional suspension of operations.
A point requiring special attention: 6 months after the first crypto-asset service provider is licensed, domestic investors trading crypto assets outside Ministry of Finance-licensed providers may face administrative sanctions or criminal liability depending on the nature and severity. Investors trading on international exchanges should watch this milestone closely.
4. What is absolutely prohibited: using crypto for payments
Despite being recognized as assets, crypto and tokenized assets are NOT lawful means of payment in Vietnam. Under Decree 52/2024/ND-CP on non-cash payments and State Bank of Vietnam regulations, lawful payment instruments do not include crypto. Using crypto to pay for goods or services may be penalized under the law.
5. Practical risks investors should know
- Trading on international exchanges: while no domestic provider is licensed yet, investors on foreign exchanges should assess legal risk, especially after the 6-month milestone above;
- Tax obligations: income from digital-asset transfers may trigger tax duties — declare and pay in full;
- Anti-money laundering: digital-asset transactions fall within the Law on Anti-Money Laundering 2022;
- Fraud: a new market with limited transparency is fertile ground for scams — conduct thorough due diligence before participating.
6. The road ahead: what is still missing?
For a complete framework, Vietnam still needs: completion of licensing and operation of pilot service providers; detailed circulars on information disclosure and risk management (the State Securities Commission is drafting); and eventually a specialized digital-assets law after the 5-year pilot. Investors and businesses should follow upcoming guidance rather than assume the framework is complete.
Frequently asked questions
Q: May Vietnamese individuals currently buy and sell crypto?
A: The law does not absolutely prohibit owning or trading crypto assets as assets, but a controlled pilot market is being rolled out and sanctions have applied since 1 September 2026. Six months after the first provider is licensed, trading outside licensed providers may be penalized.
Q: Is paying with USDT or Bitcoin a violation?
A: Yes. Crypto is not a lawful means of payment in Vietnam; using it to pay for goods or services may be penalized.
Q: What does a business need to provide crypto-asset services?
A: Under Resolution 05/2025/NQ-CP, a service provider must have charter capital of at least VND 10,000 billion and be selected among a maximum of 5 pilot organizations; dossiers go to the Ministry of Finance (accepted since 20 January 2026).
Does your business need legal advice on digital assets, transaction structuring or compliance during the pilot phase? Contact us for advice.
This article was prepared by the FLAW AI Legal Council. Its content is pending QA Council review before submission for approval; the information is for reference only and does not replace legal advice for your specific case.