Vietnam has officially launched a ambitious, five-year pilot program to regulate cryptocurrency trading, marking a significant shift from a period of informal activity to a state-supervised market. However, the initiative, governed by Resolution No. 05/2025/NQ-CP, is facing early challenges, having received no formal applications from businesses since its announcement in September 2025.
A High Bar for Entry
The government’s framework is designed with strict safeguards, setting a very high barrier for potential crypto exchanges. The goal is to ensure that only the most substantial and compliant enterprises can participate.
The most notable requirement is the minimum charter capital of VND 10 trillion (approximately US $379 million), a figure that is comparable to the capital required for full commercial banks and far exceeds requirements in other Southeast Asian jurisdictions like Singapore or Hong Kong. Furthermore, the ownership structure is tightly controlled, with a cap of 49% for foreign investors and a rule mandating that at least 65% of equity be held by institutional investors. All trading must be settled in the Vietnamese Dong (VND), and the issuance of stablecoins or assets backed by securities is prohibited.
Bridging the Gap Between Regulation and a Thriving Market
This cautious regulatory approach exists alongside a market that is already booming. Vietnam is a global leader in crypto adoption, with over $220 billion in crypto asset flows recorded in 2025 and an estimated 17 million Vietnamese trading on offshore platforms. The government’s clear objective is to bring this massive, informal economic activity onshore where it can be regulated, taxed, and integrated into the national financial system.
The immediate challenge, however, is the lack of applicants. Experts suggest that the stringent capital rules and product restrictions are the primary hurdles, turning the pilot “from a sandbox into a closed compound” that may favor large financial groups over fintech innovators. The absence of early applicants is seen not as a lack of interest, but as hesitation amid the regulatory uncertainty and stringent readiness requirements.
The future of Vietnam’s regulated crypto market now hinges on whether the government’s timeline to license the first enterprise before 2026 can be met, and if the high barriers can successfully foster a secure and liquid domestic market without stifling the innovation and activity they seek to capture.
