Among the components of the International Financial Centre under Resolution 222/2025/QH15, the exchange is the most anticipated and also the one with the thinnest legal frame. The Resolution stops at the orientation of forming commodity and digital asset exchanges inside the IFC; no licensing model has been issued, so this article separates what is already clear as orientation from what remains purely expected.
What Resolution 222/2025/QH15 actually orients: an exchange, but no detailed rulebook yet
Resolution 222/2025/QH15 establishes the IFC in Ho Chi Minh City and Da Nang together with a membership regime, and within the centre’s market structure it orients the organisation of specialised exchanges, including a commodity exchange and digital asset trading. This is a statement at National Assembly resolution level: it affirms the policy and the authority to build the regime, but it does not by itself create a licence, set capital conditions for an exchange operator or list the assets that may be traded.
The practical consequence is that as at 21 October 2026 no organisation can file a complete IFC exchange licence dossier, because no focal authority, forms or approval criteria have been published. Interested enterprises should watch two upcoming layers of documents: the Government decree implementing Resolution 222/2025/QH15 and the rules of the IFC governing authority in each city, where the licensing model will most likely be specified.
Digital assets in the IFC must be read next to the nationwide crypto-asset pilot
Any discussion of a digital asset exchange in the IFC must sit next to Resolution 05/2025/NQ-CP on piloting the crypto-asset market nationwide. The two frames risk overlapping: one is a sectoral pilot led by the financial regulator, the other a territory-based special regime of the IFC. Until a delineating document appears, the prudent assumption is that crypto-asset trading inside the IFC must still respect the principles of the nationwide pilot frame, except where Resolution 222/2025/QH15 and later guidance expressly provide otherwise.
On asset classes, there is no official list for an IFC exchange yet. Market discussion often mentions commodity derivatives linked to agricultural products, metals and energy, and digital assets recognised within the pilot frame, but all of this remains expected rather than decided. Investors should not sign issuance or listing commitments based on a guessed list; products should be designed modularly so they can be adjusted when the real list is published.
Operator conditions: what can be prepared now even without a licensing rulebook
Experience from markets with licensed exchanges suggests three condition groups will almost certainly appear in the IFC rules: financial capacity and capital of the operator; technology infrastructure covering matching, custody and clearing with real-time surveillance capability; and risk governance including trading rules, circuit breakers, segregation of client assets and anti-money laundering. This is preparation analysis based on market practice, not a quotation of IFC rules, and this article states that nature expressly so readers do not mistake it for an issued requirement.
The participation channel for foreign investors is also unformed: the likely route is indirect, through trading members that are IFC members, rather than direct accounts at the exchange. While waiting for the rules, what an enterprise can do now is register its interest with the IFC governing authority, build internal compliance capability and track the drafting progress through each Government session.
Frequently Asked Questions
Under what model will commodity and digital asset exchanges in the IFC be licensed?
Only an expected model exists so far. Resolution 222/2025/QH15 orients the formation of specialised exchanges inside the IFC, but as at 21 October 2026 no decree or rulebook defines the licensing authority, criteria or procedure for an exchange. The likely model combines an establishment and operation licence granted by the competent authority on the basis of IFC membership registration, but enterprises must wait for the official text before planning against specific timelines.
Which types of digital assets are expected to be traded on an exchange in the IFC?
There is no official list. Market discussion covers digital assets within the scope of the crypto-asset pilot under Resolution 05/2025/NQ-CP and underlying commodities for derivatives trading such as agricultural products, metals and energy. Any list outside a document of the IFC governing authority is speculation; investors should commit only when the list and the listing conditions are published in writing.
What capital, infrastructure and risk governance conditions apply to an exchange operator?
No IFC conditions have been issued to quote. Based on exchange licensing practice, an operator should prepare three groups in advance: capital and financial capacity sufficient for continuous operation; matching, custody, clearing and market surveillance infrastructure; and a risk governance frame including segregation of client assets, circuit breaker rules and anti-money laundering. This is anticipatory preparation, not a condition already in force at the IFC.
Through which channel can foreign investors trade on an IFC exchange?
No official channel has been regulated. The most prudent scenario is that foreign investors participate through trading members that have registered IFC membership, similar to how foreign investors access the Vietnamese securities market through securities companies. Direct account opening, if permitted, would need its own foreign exchange mechanism for flows into and out of the IFC, and that mechanism is also awaiting guidance.
Preparing ahead of the IFC exchange rulebook with FLAT Law Firm
FLAT Law Firm helps enterprises that want to operate or join an IFC exchange build a two-layer preparation map: compliance items that can be completed now, such as risk governance and anti-money laundering, and dossier items that must await the rulebook, such as capital conditions and the asset list. This approach keeps the enterprise from losing its waiting position while never committing beyond what Resolution 222/2025/QH15 has actually provided.
This article has been quality-reviewed by the FLAW AI Legal Council