Vietnam
Retail_Trading_Status
- Analysis ID
- #825
- Version
- Latest
- Created
- 2025-12-12 05:23
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- a1fee639...
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Executive Summary
As of December 2025, Vietnam classifies retail crypto trading as a 'Gray-Zone' activity, transitioning toward a regulated environment under a newly launched 5-year pilot program. While the government recently enacted Resolution No. 05/2025/NQ-CP to test a legal framework and the National Assembly passed the Law on Digital Technology Industry recognizing digital assets as property (effective January 2026), no licenses have yet been issued to service providers. Consequently, while trading is not criminalized for individuals, it remains operationally restricted with no active licensed venues, and the use of cryptocurrency as a means of payment for goods and services remains strictly prohibited.
Key Pillars
Ministry of Finance (MoF) & State Securities Commission (SSC) (Primary Regulators)
Resolution No. 05/2025/NQ-CP (5-Year Pilot Sandbox)
Strict AML/KYC compliance under Amended Anti-Money Laundering Law
Prohibition on using crypto as legal tender or payment instrument (Decree 52/2024/ND-CP)
Requirement for all domestic trading settlements to be in Vietnamese Dong (VND)
Landmark Laws
Resolution No. 05/2025/NQ-CP (05/2025/NQ-CP) - Enacted: 2025-09-09
- Establishes a 5-year pilot program for the crypto asset market, allowing for licensed intermediaries, defining digital assets, and setting capital requirements (VND 10 trillion) for providers.
Law on Digital Technology Industry (Law No. [Pending Number]) - Enacted: 2025-06-14
- Officially recognizes 'digital assets' as legal property under civil law for the first time; effective January 1, 2026.
Decree on Non-Cash Payments (Decree 52/2024/ND-CP) - Enacted: 2024-05-15
- Reaffirms that cryptocurrencies are not legal means of payment; prohibits their use for settlement of goods and services.
Considerations
Crypto assets are recognized as legal property but not legal tender.
A 20% Capital Gains Tax (CGT) applies to profits from crypto trading under the new pilot tax regime.
Domestic investors must eventually trade only through licensed providers, none of which are operational as of Dec 12, 2025.
Strict foreign ownership caps (49%) apply to licensed service providers.
Banking access is restricted; foreign investors must open dedicated VND accounts.
Notes
The analysis reflects the regulatory environment as of December 12, 2025. The 'Gray-Zone' determination is driven by the fact that while a pilot framework (Resolution 05) exists, the market is not yet 'Allowed-Regulated' in practice because no licenses have been issued and the primary law (Digital Tech Industry Law) is not effective until Jan 1, 2026. Retail investors are currently in a gap period where the old 'wild west' is ending but the new regulated gates haven't opened.
Remaining Uncertainties
- When the first VASP license will be officially granted to activate the regulated market.
- How the transition period for existing investors holding assets on offshore exchanges will be managed.
- Specific technical standards for the 'real underlying assets' required to back issued tokens.
Detailed Explanation
Detailed Explanation
As of December 2025, Vietnam classifies retail cryptocurrency trading as a 'Gray-Zone' activity, signifying a transitional phase toward a regulated market. This status is driven by the existence of a new legal framework that is not yet fully operational. The government enacted Resolution No. 05/2025/NQ-CP on September 9, 2025, establishing a 5-year pilot program for the crypto asset market, which defines digital assets and sets capital requirements for service providers. Furthermore, the National Assembly passed the Law on Digital Technology Industry on June 14, 2025, which for the first time legally recognizes digital assets as property under civil law, effective from January 1, 2026. However, no licenses have been issued to service providers under the pilot program as of December 12, 2025, leaving retail trading in a practical limbo where it is not criminalized for individuals but remains operationally restricted with no active, licensed domestic trading venues. The primary regulatory bodies overseeing this emerging framework are the Ministry of Finance (MoF) and the State Securities Commission (SSC). Key requirements under the new regime include strict Anti-Money Laundering and Know Your Customer (AML/KYC) compliance as mandated by the Amended Anti-Money Laundering Law, a prohibition on using cryptocurrency as a legal means of payment for goods and services as reaffirmed by Decree 52/2024/ND-CP, and a requirement for all domestic trading settlements to be conducted in Vietnamese Dong (VND). A 20% Capital Gains Tax (CGT) applies to profits from crypto trading under the new pilot tax regime. For the market to become fully regulated, domestic investors will eventually be required to trade only through licensed providers, which must meet a substantial capital requirement of VND 10 trillion and are subject to a strict 49% foreign ownership cap. Banking access remains restricted, with foreign investors required to open dedicated VND accounts. The current 'Gray-Zone' determination reflects this gap period where foundational laws are passed but the regulated market infrastructure is not yet live, creating a scenario where the old unregulated environment is ending before the new gates have officially opened.
Summary Points
I. Regulatory Status
* Vietnam's retail cryptocurrency trading is classified as a 'Gray-Zone' activity as of December 2025.
* The country is in a transitional phase, moving from an unregulated environment toward a regulated framework under a newly launched pilot program.
* No operational licenses have been issued to service providers, meaning the market is not yet 'Allowed-Regulated' in practice.
II. Key Regulatory Bodies
* Ministry of Finance (MoF)
* State Securities Commission (SSC)
III. Important Legislation
* Resolution No. 05/2025/NQ-CP (Enacted: 2025-09-09)
* Establishes a 5-year pilot program for the crypto asset market.
* Allows for licensed intermediaries and defines digital assets.
* Sets a capital requirement of VND 10 trillion for service providers.
* Law on Digital Technology Industry (Enacted: 2025-06-14; Effective: 2026-01-01)
* Officially recognizes 'digital assets' as legal property under civil law for the first time.
* Decree on Non-Cash Payments (Decree 52/2024/ND-CP) (Enacted: 2024-05-15)
* Reaffirms that cryptocurrencies are not legal means of payment.
* Prohibits their use for the settlement of goods and services.
IV. Compliance Requirements
* Strict AML/KYC compliance is required under the Amended Anti-Money Laundering Law.
* All domestic trading settlements must be conducted in Vietnamese Dong (VND).
* A 20% Capital Gains Tax (CGT) applies to profits from crypto trading.
* Domestic investors must eventually trade only through licensed providers (once available).
* Licensed service providers are subject to a 49% foreign ownership cap.
* Foreign investors must open dedicated VND accounts for trading.
V. Notable Restrictions or Limitations
* The use of cryptocurrency as a legal tender or payment instrument is strictly prohibited.
* No licensed trading venues are operational as of December 12, 2025, creating operational restrictions for retail investors.
* Banking access for cryptocurrency activities remains restricted.
VI. Recent Developments or Notes
* The analysis reflects the regulatory environment as of December 12, 2025.
* The 'Gray-Zone' status exists because the pilot framework (Resolution 05) is in place and property rights are recognized (via the Digital Tech Industry Law), but the primary law is not yet effective and no licenses have been issued.
* Retail investors are currently in a gap period between the old unregulated environment and the new regulated system that has not yet launched.
Full Analysis Report
Full Analysis Report
As of December 12, 2025, Vietnam's regulatory stance on cryptocurrency is in a critical transition phase, moving from a long-standing 'unregulated but tolerated' status to a formal 'Gray-Zone' pilot regime. The defining development is the issuance of Resolution No. 05/2025/NQ-CP on September 9, 2025, which launched a five-year pilot program for the crypto asset market. This resolution tasks the Ministry of Finance (MoF) and the State Securities Commission (SSC) with overseeing the sector. Just days ago, on December 10, 2025, the SSC established a dedicated management board to supervise crypto asset trading, signaling the government's intent to operationalize the framework.
Despite this progress, the status remains 'Gray-Zone' because the licensing regime is not yet fully functional. While the legal framework exists on paper, no Virtual Asset Service Providers (VASPs) have been issued licenses as of mid-December 2025. The pilot program imposes high barriers to entry, including a minimum charter capital of VND 10 trillion (approx. USD 380 million) for exchanges, which has delayed the entry of compliant entities. Until licensed entities are operational, domestic investors continue to operate in a legal limbo, trading on offshore platforms or via direct arrangements that lack consumer protection.
Legally, the landscape has shifted significantly with the passage of the Law on Digital Technology Industry in June 2025. Scheduled to take full effect on January 1, 2026, this law provides the first statutory definition of 'digital assets' as a form of property, distinguishing them from securities and fiat currency. This resolves years of ambiguity regarding the property rights of crypto holders. However, the prohibition on using crypto as a means of payment remains absolute. Decree 52/2024/ND-CP, effective May 2024, explicitly excludes crypto from the list of legal non-cash payment instruments, and the State Bank of Vietnam (SBV) continues to enforce fines for using crypto to pay for goods or services.
Taxation has also been formalized under the pilot. A temporary tax policy applies a 20% Capital Gains Tax (CGT) on crypto trading profits, treating them similarly to securities, alongside a 10% VAT on service fees charged by exchanges. This replaces the previous uncertainty where tax authorities struggled to classify crypto income. However, enforcement remains a challenge given the current lack of domestic licensed on-ramps to withhold these taxes at the source.
As of December 12, 2025, Vietnam's regulatory stance on cryptocurrency is in a critical transition phase, moving from a long-standing 'unregulated but tolerated' status to a formal 'Gray-Zone' pilot regime. The defining development is the issuance of Resolution No. 05/2025/NQ-CP on September 9, 2025, which launched a five-year pilot program for the crypto asset market. This resolution tasks the Ministry of Finance (MoF) and the State Securities Commission (SSC) with overseeing the sector. Just days ago, on December 10, 2025, the SSC established a dedicated management board to supervise crypto asset trading, signaling the government's intent to operationalize the framework. Despite this progress, the status remains 'Gray-Zone' because the licensing regime is not yet fully functional. While the legal framework exists on paper, no Virtual Asset Service Providers (VASPs) have been issued licenses as of mid-December 2025. The pilot program imposes high barriers to entry, including a minimum charter capital of VND 10 trillion (approx. USD 380 million) for exchanges, which has delayed the entry of compliant entities. Until licensed entities are operational, domestic investors continue to operate in a legal limbo, trading on offshore platforms or via direct arrangements that lack consumer protection. Legally, the landscape has shifted significantly with the passage of the Law on Digital Technology Industry in June 2025. Scheduled to take full effect on January 1, 2026, this law provides the first statutory definition of 'digital assets' as a form of property, distinguishing them from securities and fiat currency. This resolves years of ambiguity regarding the property rights of crypto holders. However, the prohibition on using crypto as a means of payment remains absolute. Decree 52/2024/ND-CP, effective May 2024, explicitly excludes crypto from the list of legal non-cash payment instruments, and the State Bank of Vietnam (SBV) continues to enforce fines for using crypto to pay for goods or services. Taxation has also been formalized under the pilot. A temporary tax policy applies a 20% Capital Gains Tax (CGT) on crypto trading profits, treating them similarly to securities, alongside a 10% VAT on service fees charged by exchanges. This replaces the previous uncertainty where tax authorities struggled to classify crypto income. However, enforcement remains a challenge given the current lack of domestic licensed on-ramps to withhold these taxes at the source.
Source Evidence
Primary and secondary sources cited in this analysis
"The pilot shall be implemented on a cautious and controlled basis... The Ministry of Finance has the authority to suspend or terminate the activities of violating organizations."
"Cryptocurrency or virtual currency is not currently defined as currency and is not a form of cashless payment recognized by the State Bank of Vietnam."
"Officially recognizing cryptoassets as legal property under civil law."
"The State Securities Commission (SSC) on December 10 announced the establishment of a management board for the cryptoasset trading market."
"On September 9, 2025, the Vietnamese Government issued Resolution No. 05/2025/NQ-CP... marking the first time a formal legal framework has been established."
Web Sources (7)
Sources discovered via web search grounding
Search queries used (5)
- Vietnam Ministry of Finance crypto legal framework 2025
- Vietnam crypto tax laws for individuals 2024
- Vietnam FATF virtual asset regulation progress 2025
- Vietnam cryptocurrency regulation status retail trading 2024 2025
- State Bank of Vietnam crypto circular payments vs trading
https://vir.com.vn/mof-to-launch-pilot-framework-to-regulate-crypto-market-137972.html
https://www.panewslab.com/en/articles/971aa47f-5854-46c8-9c31-7b13dc8ea540
https://www.tilleke.com/insights/vietnams-emerging-regulatory-landscape-for-blockchain-and-cryptocurrency/34/
https://www.allenandgledhill.com/vn/publication/articles/31333/establishes-digital-technology-framework-and-launches-crypto-asset-market-pilot-program
https://vietnamlawmagazine.vn/government-resolves-to-facilitate-crypto-asset-market-operation-75266.html
https://aurpay.net/aurspace/vietnam-cryptocurrency-regulation-379-million-barrier-analysis/
https://vir.com.vn/vietnam-establishes-management-board-for-crypto-asset-trading-market-142712.html