Crypto assets in Vietnam moved from a grey zone into a pilot framework within a year: the law recognises digital assets as property and the Government opened a licensed trading-market pilot, yet a domestic exchange for local investors is still not a freely launchable service. Investors entering this space must read three overlapping legal layers correctly.
The legal picture
The first layer is civil recognition: the Digital Technology Industry Law 71/2025/QH15 effective 1 January 2026 brings digital assets, including virtual assets and crypto assets, into the Civil Code property system, grounding ownership determination and dispute resolution. The second layer is the market pilot: Government Resolution 05/2025/NQ-CP of 9 September 2025 opens a five-year crypto-asset market pilot, under which a service provider needs minimum paid-in charter capital of VND 10,000 billion, foreign ownership is capped at 49 percent, transactions are in Vietnamese dong, crypto assets issued in Vietnam may be offered only to foreign investors, and the Ministry of Finance selects at most five providers for the pilot. The third layer is the prohibition boundary: crypto assets are not a lawful means of payment in Vietnam, using crypto to pay for domestic goods and services breaches payment-means rules, and Decree 284/2026/ND-CP on administrative penalties in the crypto-asset field, effective 1 September 2026, sets fines up to VND 200 million for organisations for violations in service provision and off-channel trading.
Underlying instruments
- Digital Technology Industry Law 71/2025/QH15 (effective 1 January 2026): digital assets, including virtual and crypto assets, are recognised as property under civil law.
- Resolution 05/2025/NQ-CP of 9 September 2025: a five-year crypto-asset market pilot, minimum charter capital of VND 10,000 billion, foreign ownership capped at 49 percent, at most five providers selected.
- Decree 284/2026/ND-CP (effective 1 September 2026) and payment-means rules: crypto assets are not a lawful means of payment; violations in this field draw fines up to VND 200 million for organisations.
Handling roadmap
- Map the planned business model against exactly three layers: property recognition, the pilot conditions of Resolution 05/2025/NQ-CP and the payment prohibition boundary.
- If aiming at a service-provider role, prepare the VND 10,000 billion capital plan and a foreign ownership structure not exceeding 49 percent from the start.
- Remove every feature accepting crypto assets as payment for goods and services in Vietnam from the planned product.
Where mistakes happen
The biggest risk for investors is building the model from memory of international crypto markets: an exchange for domestic retail investors, listing domestically issued tokens to the Vietnamese public, or accepting crypto as payment all fall outside the current pilot frame. Foreign investors are further capped at 49 percent ownership in a selected service provider, and selection is a Ministry of Finance decision within a limited number, not an automatic registration for whoever qualifies. While the pilot frame completes its rollout, the legally safe activities are technology and advisory services that do not touch trading, custody or crypto-based payment for Vietnamese customers.
Quick answers
Is there a legal framework yet for crypto-asset business in Vietnam?
On this question, A pilot frame exists under Resolution 05/2025/NQ-CP, but only for at most five providers selected by the Ministry of Finance with charter capital from VND 10,000 billion, not free registration. The company should align the whole team handling crypto digital asset business Vietnam on one understanding of this point.
May crypto be accepted as payment for goods and services in Vietnam?
It is important to distinguish: No, crypto assets are not a lawful means of payment in Vietnam, and accepting crypto payment domestically is prohibited, with penalties in force from 1 September 2026. This is a point to seek advice on before committing on crypto digital asset business Vietnam to a third party.
What is the maximum foreign ownership in a crypto-asset service provider?
Under the current frame, Foreign investors are capped at 49 percent ownership in a crypto-asset service provider joining the pilot. For crypto digital asset business Vietnam specifically, this point should be settled in writing in the company file.
Which law recognises digital assets as property in Vietnam and from when?
In day-to-day handling, The Digital Technology Industry Law 71/2025/QH15 recognises digital assets as property from 1 January 2026, grounding ownership and dispute handling. If the actual file on crypto digital asset business Vietnam differs from the assumptions above, the conclusion must be adjusted accordingly.
What must a company prepare to join the crypto-asset market pilot?
A company aiming at the service-provider role must prepare minimum paid-in charter capital of VND 10,000 billion, a foreign ownership structure not exceeding 49 percent, trading and custody systems operating in Vietnamese dong, and a risk-governance capability file for the Ministry of Finance to consider within the maximum of five providers selected for the pilot.
This article has been quality-reviewed by the FLAW AI Legal Council