Vietnam’s crypto asset market gained an official pilot door through Government Resolution 05/2025, but that door is designed for very few businesses: the capital and shareholder conditions make a pilot exchange a game for large financial institutions, not small startups.
Legal basis to know
Resolution 05/2025/NQ-CP of 9 September 2025 on piloting the crypto asset market sets the frame for offering, issuing crypto assets and organizing trading markets in Vietnam, with the Ministry of Finance licensing organizations providing crypto asset trading market services. Core licensing conditions include: a Vietnamese enterprise under the Law on Enterprises, paid-up charter capital of at least VND 10,000 billion in Vietnamese dong, at least 65% of charter capital held by organizations of which over 35% comes from at least two organizations in the commercial bank, securities company, fund management, insurance or technology groups, total foreign ownership not exceeding 49%, and information technology systems meeting level-4 security standards. The Digital Technology Industry Law 71/2025/QH15 adds the foundation recognizing digital assets from 1 January 2026.
How this applies in practice
The condition design shows the pilot’s goal is testing the market under control rather than mass opening: requiring large financial institution shareholders to participate deeply forces a pilot exchange to operate to financial-sector governance standards from day one. For individual investors, the biggest change is that trading on a domestically licensed exchange becomes a recognized lawful channel, replacing self-directed trading on foreign platforms in the grey zone. Small businesses wanting into this ecosystem realistically can only be ancillary service providers or technology partners to licensed organizations.
What to do now
- Investors wanting to run an exchange should test the three hard conditions before anything else: VND 10,000 billion capital, the institutional shareholder structure and level-4 system security.
- Individual investors should trade only via organizations licensed by the Ministry of Finance in the pilot and keep transaction records for tax and declaration duties.
- Small technology companies should position as infrastructure, custody or compliance providers to licensed exchanges rather than seeking a market-organizer licence themselves.
Frequently Asked Questions
Does Vietnam allow pilot crypto asset exchanges?
Yes, Resolution 05/2025/NQ-CP of 9 September 2025 officially pilots the crypto asset market in Vietnam, including licensing organizations that provide crypto asset trading market services; outside the pilot scope and without a licence, opening a crypto asset exchange still lacks a legal basis.
What are the conditions to operate a pilot digital asset exchange?
The central conditions are: a Vietnamese enterprise, paid-up charter capital of at least VND 10,000 billion in dong, at least 65% of capital held by organizations with over 35% from at least two organizations in the commercial bank, securities, fund management, insurance or technology groups, foreign ownership capped at 49%, level-4 system security standards and a licence from the Ministry of Finance.
Can individual investors trade on pilot exchanges?
Vietnamese and foreign individual investors are within the pilot’s participant scope and may trade on domestically licensed organizations; this is a fundamental difference from before, when individuals mainly traded on foreign platforms in an area without a clear legal framework.
This article has been quality-reviewed by the FLAW AI Legal Council