To move from initial clearance to a full operating license, each firm must meet two additional requirements set by Vietnam’s Ministry of Finance:
- Level 4 information system security certification
- Minimum charter capital of VND 10 trillion, roughly $383 million
A Framework Built on Tokenized Real-World Assets
The regulatory structure traces back to Government Resolution No. 05/2025/NQ-CP, signed September 9, 2025. Under the pilot, every tokenized asset traded on a licensed platform must be backed by a real-world asset and issued by a Vietnamese entity. Securities and fiat currencies are explicitly excluded from the tokenized asset category, and all settlements must be conducted in Vietnamese Dong.
Foreign investors get market access first. Domestic investors will not be required to trade exclusively through licensed platforms until six months after the Ministry of Finance issues its first exchange license, a threshold none of the five companies have yet cleared.
Additional structural rules include:
- Foreign ownership in any licensed exchange is capped at 49%
- No exchange license has been issued as of this report
- Operations could begin as early as the third quarter of 2026, pending final approval
Why the Timing Matters
Vietnam currently ranks among the top seven countries globally for crypto adoption, with an estimated 17 million holders, most of them trading through platforms with no formal domestic licensing. Once the September 1 penalty regime takes effect, that entire user base faces a choice: migrate to licensed platforms once they exist, or continue operating in a market now explicitly classified as illegal outside the approved framework.
