Vietnam

Other Developments

Among the applicants, the VPBank-linked entity CAEX is reported to have secured backing from OKX Ventures and HashKey Capital around April 2026 while working toward the pilot's capital requirements. The amount of that backing has not been publicly disclosed in the sourcing available, and this finding carries Uncertain confidence given the lack of corroboration beyond a single report.

Cross-Monitor Connections

The commercial positioning among bank- and securities-affiliated applicants for crypto-exchange pilot licences intersects with Vietnam's broader financial-sector structure, in which large domestic banks and brokerages are seeking to anchor regulated crypto-asset trading within existing institutional relationships. This is noted here as a commercial-activity finding; it is not an assessment of AML/CFT exposure, which sits outside this module.

Outlook

The question to watch is whether the Ministry of Finance issues the first licence under the pilot, which would trigger the six-month transition period toward mandatory licensed domestic trading under Decree No. 284/2026. Until a licence is issued, the five applicants' commercial positioning - including CAEX's disclosed but unquantified backing - remains preparatory rather than operative.

1 earlier update not shown here.

Standing brief · as of 25 August 2026

Written before the update above. Where they differ, the update is the more recent position.

Lead Signal

Vietnam exited its crypto gray zone this cycle with the effective operation of a hard-law, though still pilot-stage, licensing regime. Law No. 71/2025/QH15 and Resolution No. 05/2025/NQ-CP took effect from 1 January 2026, and Ministry of Finance Decision No. 96/QD-BTC formally launched the licensing pathway for crypto-asset trading platforms under the resolution's five-year pilot. Only Crypto Asset Service Providers incorporated in Vietnam as limited liability companies or joint-stock companies, holding a minimum charter capital of VND 10,000 billion, may operate exchange and custody services under the pilot. This is a decisive architectural shift from an unregulated environment to a licensed one, but the licensing terms themselves, the capital threshold and the local-incorporation requirement, confine near-term market entry to well-capitalised, domestically established incumbents, meaning the shift from gray zone to hard law does not, by itself, translate into an open market for new entrants. The pilot's structure, a fixed five-year window running 2025 to 2030 across two implementation phases, with taxation and accounting rules following on a separate track, signals that Vietnam is treating crypto-asset regulation as a staged experiment rather than a permanent settlement, a posture consistent with the broader civil-law pattern of enabling-instrument-plus-implementing-decree sequencing seen elsewhere in Vietnam's regulatory practice this cycle. All of this cycle's findings across crypto licensing, token classification, denomination, tax accounting and cross-border access rest on Tier-3 or Tier-4 legal-commentary and industry-analysis sourcing rather than directly retrieved Ministry of Finance or State Bank of Vietnam primary text, a sourcing characteristic of tracking a fast-moving pilot regime in this jurisdiction rather than a defect in the underlying findings themselves.

Other Developments

Virtual assets recognised as property. Law No. 71/2025/QH15 classifies virtual assets, cryptocurrencies, non-fungible tokens and utility tokens as property under Vietnamese civil law, conferring ownership, transfer, inheritance and dispute-resolution rights. This foundational classification is the legal predicate for the custody, ownership and transfer provisions the licensing pilot in turn regulates, though a more granular taxonomy distinguishing token types beyond the general property classification has not been evidenced this cycle. The property classification's practical significance is that it gives digital-asset holders standing to assert ownership, seek judicial remedy for wrongful transfer, and pass digital assets through inheritance, placing crypto assets on a comparable legal footing to other recognised forms of property under Vietnamese civil law, well before the licensing pilot's capital and incorporation requirements determine who may lawfully provide exchange and custody services around those assets.

Denomination and tax-accounting rules attach to the pilot. All offering, issuance, trading and payment transactions conducted under the Resolution 05 pilot must be denominated in Vietnamese Dong, a requirement that bears on foreign-currency-referenced digital-asset activity without constituting a dedicated stablecoin framework. Separately, Circular 15/2026/TT-BTC requires that crypto trading and corporate crypto holdings be processed under accounting principles similar to financial investments and securities, establishing an accounting baseline even though specific capital-gains, value-added-tax and withholding-tax rates remain unsourced this cycle. Read together, the VND-denomination requirement and the Circular 15 accounting-treatment rule describe a pilot that is being built with domestic-currency and domestic-accounting integration as first-order design features rather than afterthoughts, consistent with a regulator seeking to keep the pilot's activity visible and reconcilable within existing domestic financial-reporting and foreign-exchange frameworks rather than allowing a parallel, harder-to-supervise foreign-currency-denominated market to develop alongside it.

Foreign investors gain a licensed onramp. For the first time, Resolution No. 05/2025/NQ-CP gives foreign investors legitimate access to Vietnam's digital-asset market through licensed domestic platforms, including exclusive opportunities to purchase digital assets issued by Vietnamese companies. This is a market-access development with a cross-border dimension rather than a dedicated cross-border-transfer or travel-rule framework, and it should be read narrowly as an inbound-investment access provision tied to the licensed pilot platforms. This onramp is exclusive to licensed domestic platforms operating under the pilot, meaning it does not extend to foreign investors seeking to access Vietnamese digital assets through offshore exchanges or platforms outside the licensed perimeter; the practical scope of the onramp is therefore bounded by the same capital-and-incorporation licensing terms that gate the crypto_licensing module more broadly.

Cross-Monitor Connections

Vietnam's AML/CFT regime as it applies to crypto-asset service providers is tracked under the aml_cft_regime module by the financial-integrity monitor as producing consumer this cycle, and is not re-analysed here; readers seeking that analysis should consult the financial-integrity brief for this jurisdiction. Separately, the financial-integrity monitor's own D5 (Crypto, Digital Assets and Financial Innovation) tracking for this cycle covers the same Ministry of Finance Decision No. 96/QD-BTC pilot launch from an anti-money-laundering and FATF-action-plan-compliance lens, a complementary but distinct reading of the same underlying instrument from the one presented here. This division of labour is deliberate rather than a gap: the fleet's single-owner rule assigns aml_cft_regime content to the financial-integrity monitor as producing consumer for this jurisdiction, and this brief's silence on AML/CFT specifics for crypto-asset service providers reflects that assignment rather than an absence of relevant findings.

Outlook

The five-year pilot proceeds through two implementation phases, and the taxation and accounting rules issued under Circular 15/2026/TT-BTC are an early indication of phase-specific rules following the initial licensing launch. The clearest open questions for the next cycle are whether specific tax rates under Circular 15 are published, whether a dedicated stablecoin instrument emerges beyond the pilot's VND-denomination requirement, and whether DeFi, staking or mining activity is addressed within the pilot framework or left unregulated, a question this cycle's research pass could not resolve. Beyond the specific pilot-phase and stablecoin questions, the more structural question for next cycle is whether primary-source retrieval from the Ministry of Finance or State Bank of Vietnam becomes available, which would allow this module's confidence levels to move beyond the current Tier-3/4 legal-commentary ceiling toward genuinely confirmed status.