Vietnam Implements New Licensing System for Cryptocurrency Exchanges

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Vietnam has introduced its first licensing regime for cryptocurrency exchanges under its new Resolution No. 05/2025/NQ-CP, establishing strict capital, ownership, and compliance requirements within a five-year pilot framework.

On September 9, 2025, the Government of Vietnam issued Resolution No. 05/2025/NQ-CP (“Resolution 5”)

This groundbreaking step marks the introduction of a formal licensing regime for cryptocurrency exchange services, aligning Vietnam with global trends in the regulation of digital assets.

The move follows the passage of the Law on Digital Technology Industry in June 2025, which laid the groundwork for developing Vietnam’s digital economy. Together, these measures mark a decisive step in Vietnam’s effort to bring cryptocurrency trading and related activities into a regulated framework, strengthen oversight of digital financial markets, and align with international anti-money laundering and financial compliance standards.

Enterprises wishing to operate cryptocurrency exchanges in Vietnam must adhere to a multi-step registration process outlined by Resolution 5, reflecting the government’s cautious but progressive approach to digital assets.

Regulatory Context

The licensing framework under Resolution 5 is part of a broader strategy to develop Vietnam’s digital economy. Grounded in the Digital Technology Law passed by the National Assembly in June 2025, this new legal framework recognizes digital assets as valid property under the law.

The introduction of this licensing regime allows for a controlled market where both domestic and foreign investors can participate in cryptocurrency activities, significantly enhancing the government’s oversight capabilities.

Oversight is a shared responsibility among multiple regulatory bodies, including the Ministry of Finance (MOF), State Securities Commission (SSC), State Bank of Vietnam (SBV), and Ministry of Public Security (MPS). The MOF leads the licensing review process, ensuring compliance and safeguarding financial security.

Definition of Crypto Assets

Resolution 5 formally defines crypto assets, authenticating them through encryption and ensuring they are distinctly categorized from securities, fiat currencies, and other established financial instruments within Vietnam’s legal system. This recognition allows for ownership, transfer, and inheritance rights, thus establishing crypto assets as a legitimate category within Vietnamese law.

Licensing Procedure for Cryptocurrency Exchanges

The licensing procedure under Resolution 5 is outlined in several stages to ensure thoroughness while promoting innovation:

Step 1: Initial Dossier Submission

Enterprises must begin by submitting a dossier to the SSC, which should include an application form, company charter, registration documents, and operational procedures that cover trading, custody, and risk management.

Step 2: MOF Review

The MOF reviews the dossier for completeness and responds within 20 working days. Incomplete applications will be returned with guidance for correction.

Step 3: Supplemental Dossier Submission

Within 12 months of receiving MOF confirmation, enterprises must submit supplementary documentation, including:

• A complete list of shareholders and proof of capital contributions, confirming a minimum charter capital of VND 10,000 billion (approximately USD 378 million);
• Evidence that foreign ownership does not exceed 49 percent;
• A security appraisal by the MPS;
• Proof of a registered Vietnamese headquarters;
• Audited financial statements to demonstrate solvency and operational capacity.

Step 4: Appraisal and License Issuance

Once the supplemental dossier is reviewed, the MOF, in collaboration with the SBV and MPS, will issue a license within 30 days, provided all conditions are met.

Step 5: Post-Licensing Disclosures

Licensed exchanges must publish their operating licenses on the MOF website, their business website, and national newspapers, ensuring transparency for stakeholders.

Step 6: Commencement of Operations

Licenses must be activated within 30 days of issuance. Otherwise, they risk revocation. Compliance with these timelines is crucial for maintaining operational legitimacy.

Compliance and Business Requirements

To qualify for a cryptocurrency exchange license, enterprises must meet stringent standards that prioritize financial stability and investor protection:

• Capital Requirements: A minimum charter capital of VND 10,000 billion is necessary, filtering market entry to well-capitalized entities.
• Ownership Structure: At least 65 percent of equity must be held by institutional investors, with foreign ownership capped at 49 percent, safeguarding domestic financial institutions.
• Personnel Requirements: Key staff must have qualifications in both finance and IT, ensuring technical expertise within the exchanges.
• System Security Standards: Compliance with Level 4 certification for security is mandatory, incorporating robust cybersecurity protocols.
• Transaction Currency: All transactions must occur in Vietnamese Dong (VND).

Opportunities for Foreign Businesses and Investors

The resolution opens up a structured regulatory framework for engaging with crypto assets while preserving essential government oversight. This selective model aims neither for a complete ban nor unfettered activity, balancing economic innovation with risk mitigation.

This nuanced approach positions Vietnam favorably amid global extremes of cryptocurrency regulation, comparable to other Southeast Asian nations like Singapore and Thailand, which initially implemented stringent guidelines before transitioning to a more liberal environment.

However, the pilot program brings challenges as well. Key considerations involve potential future permissions for crypto assets as payment and capital contributions, the need for distinct regulations across various token categories, and whether the high capital requirements might dissuade smaller innovators.

The government has reserved the right to suspend operations if necessary, reaffirming its cautious approach while establishing a legal framework that affords rights and protections.

As Vietnam continues to navigate the evolving cryptocurrency landscape, the introduction of this licensing regime signals a significant shift toward a regulated market, inviting foreign businesses and investors to participate in a promising new sector.

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