Vietnam's Five-Year Crypto Pilot Program: Rules, Impact, and What Changes by 2027

Vietnam has just taken a bold step: the world’s first comprehensive legal framework for digital assets, rolled out as a five‑year pilot that started on 9 September 2025 and runs until 8 September 2030. The goal? Turn a market that was once fully prohibited into a regulated space where crypto can be bought, sold, and invested - but only through licensed channels.

Below, we break down what the pilot actually means for investors, service providers, and the broader economy, and why the next two years (up to 2027) are the most critical for anyone watching Vietnam’s crypto evolution.

What the Pilot Program Looks Like

Vietnam's Five-Year Pilot Cryptocurrency Program operates under two key pieces of legislation:

• Law No. 71/2025/QH15 on Digital Technology Industry, passed 14 June 2025.
• Resolution 05/2025/NQ-CP, signed by Deputy Prime Minister Ho Duc Phoc on 9 September 2025.

The law officially recognises “virtual assets” as legitimate property under the Civil Code. Within that umbrella, three categories are defined:

1. Virtual assets (general definition, excluding securities and legal tender).
2. Crypto assets - the subset that relies on encryption or similar digital tech for creation, issuance, storage, and transfer.
3. Other virtual assets that don’t fit the first two categories.

The Ministry of Finance is the lead regulator, responsible for licensing all crypto‑asset service providers. The first licence is expected within six months of the resolution’s effect, meaning the market will see a rapid shift from informal exchanges to officially approved platforms.

Who Can Participate?

Both domestic and foreign investors are allowed to trade, provided they use a licensed provider. The pilot does not lift the State Bank of Vietnam’s ban on using crypto as a payment method, but it does legalise ownership and trading.

• Investors: Individuals, funds, and corporations can hold and trade crypto assets on licensed exchanges.
• Service providers: Exchanges, custodians, and wallet operators must obtain a licence from the Ministry of Finance.
• Issuers: Projects issuing new tokens need to register and comply with AML, terrorism‑financing, and cybersecurity standards.

Key Compliance Requirements

Compliance is the toughest part of the pilot. Participants must meet a suite of obligations:

• Anti‑Money Laundering (AML): Detailed customer‑due‑diligence, transaction monitoring, and reporting to authorities.
• Cybersecurity standards: Providers must implement ISO‑27001‑type controls and undergo regular penetration testing.
• Information security: Secure data storage, encryption of private keys, and mandatory breach notifications.
• Tax reporting: Until specific crypto tax rules are issued, existing securities tax rates apply.

Failure to comply can result in administrative fines or criminal investigations, depending on the severity.

How Vietnam’s Approach Differs From Its Neighbours

Vietnam’s model sits somewhere between China’s outright ban and the EU’s detailed MiCA rules. The biggest difference is the strict mandate that all domestic transactions shift to licensed providers within a six‑month window after the first licence is issued.

Market Reaction So Far

Data from the Vietnamese Information & Research (VIR) group shows daily crypto transaction volumes exceeding $600 million. That surge reflects pent‑up demand from years of prohibition. However, traders are scrambling to move activity from offshore exchanges to the soon‑to‑be‑licensed domestic platforms.

Social‑media chatter on Reddit’s r/VietnamCrypto and local forums is a mix of excitement and caution. Users applaud the legal clarity but worry about the cost and speed of compliance. A typical thread reads:

“It’s great that the government finally says crypto is legal, but the licensing paperwork looks like a nightmare. Small traders may get pushed out.”

Industry observers, including Dr. Tran Quy of the Vietnam Institute for Digital Economy Development, argue the pilot will “open a controlled runway for technology, capital and innovation to take off.” Yet legal firms such as Duane Morris Vietnam warn that “the lack of detailed tax guidance and mining regulations could slow adoption.”

Steps for Service Providers to Get Licensed

If you run an exchange or custodian, here’s the practical roadmap that most firms are following:

1. Prepare a comprehensive AML/KYC policy that aligns with the Ministry of Finance’s draft guidelines.
2. Implement ISO‑27001‑style cybersecurity controls and obtain third‑party audit reports.
3. Submit an application package containing corporate registration, capital adequacy proof (minimum VND 500 billion), and a detailed business plan.
4. Undergo a technical inspection of your trading engine and wallet infrastructure.
5. Await the Ministry’s approval - expected turnaround is 60‑90 days once all documents are accepted.

During the pilot phase, the Ministry has promised a “sandbox” environment for testing innovative services, but participation is limited to firms that already hold a provisional licence.

Potential Risks and How to Mitigate Them

Even with an official framework, risks remain:

• Regulatory capture: Larger financial institutions may dominate licences, sidelining smaller startups. Mitigation: Form alliances or merge with established fintech firms to meet capital thresholds.
• Cross‑border friction: International exchanges might face difficulties aligning with Vietnam’s AML rules. Mitigation: Use local custodians to bridge compliance gaps.
• Enforcement uncertainty: Penalty structures are still being drafted. Mitigation: Adopt a “best‑practice” stance now - treat the pilot as if full penalties already apply.

Looking Ahead to 2027 and Beyond

By the end of 2027, the pilot will have completed two full years of operation. Analysts expect three clear outcomes:

1. Data‑driven policy tweaks: The Ministry will use transaction data to fine‑tune AML thresholds and tax rates.
2. Institutional entry: Large Vietnamese banks are likely to launch crypto‑linked products, such as custodial services for high‑net‑worth clients.
3. Regional leadership: Vietnam could become the go‑to hub for Southeast Asian crypto firms seeking a regulated environment, especially as Thailand and Singapore tighten their own licensing regimes.

For investors, the key takeaway is to stay on licensed platforms, keep thorough records, and watch for the Ministry’s tax guidance - expected before 1 January 2026 when the full law takes effect.

Quick Checklist for Anyone Involved

• Verify that your exchange or wallet provider holds a Ministry of Finance licence.
• Maintain KYC records for at least five years.
• Implement multi‑factor authentication and cold‑storage solutions for crypto holdings.
• Track any tax notices - treat crypto gains as securities until specific rules appear.
• Monitor official announcements from the Ministry for updates on mining regulations and penalty structures.

Frequently Asked Questions

Vietnam’s crypto pilot is still a work in progress, but the direction is clear: regulated access, strict compliance, and a vision to become a regional hub. If you’re planning to trade, invest, or launch a service, the next two years will set the foundation for everything that follows.