Vietnam

{
  "analysis_text": "As of December 12, 2025, Vietnam\u0027s regulatory stance on cryptocurrency is in a critical transition phase, moving from a long-standing \u0027unregulated but tolerated\u0027 status to a formal \u0027Gray-Zone\u0027 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\u0027s intent to operationalize the framework.\n\nDespite this progress, the status remains \u0027Gray-Zone\u0027 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.\n\nLegally, 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 \u0027digital assets\u0027 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.\n\nTaxation 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.",
  "confidence_level": "High",
  "executive_summary": "As of December 2025, Vietnam classifies retail crypto trading as a \u0027Gray-Zone\u0027 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.",
  "grounding_urls": [
    {
      "resolved_url": "https://vir.com.vn/mof-to-launch-pilot-framework-to-regulate-crypto-market-137972.html",
      "title": "vir.com.vn",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEUoTVaY5aleORvbgJVo0XuFhKO6EgZ5y5I7Mk0DBMOYtBQzKoCRxypbjvOGpE7FqtOMkQ6PZt7R3y07XxCAHESzyQNsWPifhlA7nR1qLWdVjHrfWCzqavmrBl1siGSi0nJxhaM_h3YVzmSPLDLS95U9x8a-ZuRwrTxG5vT-QSDP0ioJKuUnGWoim003-Er8u6D"
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    {
      "resolved_url": "https://www.panewslab.com/en/articles/971aa47f-5854-46c8-9c31-7b13dc8ea540",
      "title": "panewslab.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEOMU70k9hkYRs_UcQpg5gXl8Jpe2gNCpEzQx90vBD7iQrWedrLc0VzMaSZgVEfiz8rJkbXl0Kr_RUohMZm_ViW_wdHhqMkOv94SPJdq7cVl2eJ6IP2rPRPnnVvjrsaWWjsRGGytUZ8ElTk8lYcRnB-Ljh83rF6eyXHwvNruV_tSpL-RITC"
    },
    {
      "resolved_url": "https://www.tilleke.com/insights/vietnams-emerging-regulatory-landscape-for-blockchain-and-cryptocurrency/34/",
      "title": "tilleke.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFa6RzMkwRXHHzXi1RtuHm-PXFH7G45Erz2dF_AZzrd5dQXxRaglMTqGPYHKrk1MZgHQn_vrCvDj8ZAezDC08AlfspQwXqKJSQ_2qO41VOlMryXDXDo2Lu6DL-0a-nhMeG7U247mQS2O78aW08PLX2hzOg8BT-zX9ca-pSSJXXIHZ6kZWyPIq2BDKTKoUURJXoQVOcybUu4UWXRBoNIsfQZbkRpvd6vktQ="
    },
    {
      "resolved_url": "https://www.allenandgledhill.com/vn/publication/articles/31333/establishes-digital-technology-framework-and-launches-crypto-asset-market-pilot-program",
      "title": "allenandgledhill.com",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFnWK2x8ZAsca7iaj9_iHvbMmBgLE78EFEiwJdH5pjlspVK_q0oGcxwMrDUL8XIlVw9IX6qd16wV5x6hH8kdil4RUn7vebhCPcGipAaCBwUuGFvINmL5LYo8k2JYLDKUHVqKhNPha9LXDbwPctg1qNTUo4mbubLjvGhJ__N-0WOU-oO3ckF7_BgAcfGiqK-WGPFeyBYxv3VkBeDsuQWu5sz3W9YvHYDGxy2bYxPNM7xKL8wqQS-XAX07rEtQ3x3Wm8JLxpYtX3VSyxJ2jhyQ69DjdA="
    },
    {
      "resolved_url": "https://vietnamlawmagazine.vn/government-resolves-to-facilitate-crypto-asset-market-operation-75266.html",
      "title": "vietnamlawmagazine.vn",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQFSXpI7eMbOcyclqMPTN_W7gKj-46unl8zRlQOaV11upUQ9OofoCwbhrzUS57-PpHtv35AiDIrfO99XjoB5o4KcL6hLHUF-E13AoGxobyLIZwntNlbxH4oxi8_DyewcoJfxWmUaFAM75Bfxw9xTRO8SdocjJeuAa959SK8EsBAZgu02T5lwIJ2V65nNLQjpePtYYEz7NqNsfN9Ou7aHv5Z_TxnG"
    },
    {
      "resolved_url": "https://aurpay.net/aurspace/vietnam-cryptocurrency-regulation-379-million-barrier-analysis/",
      "title": "aurpay.net",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQGc0L3qIontrR5J30CPMKfcyajkWQftGv5QwhhsoWmewV1vRDAHDy3aDa2PdgDVRQtBptXN0xXFmx4NbW-pI9Y99wG31Najp5C8Fg3EyQhzVnuyORQ8pPZEpsL-uOJshSQSZXwTrxHs7_D3Evh4KN06UnUUCNJQi7NXUOQK1ZCoPmvsjLnWEQT1HW1s59-YHKizTZ5tZbs="
    },
    {
      "resolved_url": "https://vir.com.vn/vietnam-establishes-management-board-for-crypto-asset-trading-market-142712.html",
      "title": "vir.com.vn",
      "url": "https://vertexaisearch.cloud.google.com/grounding-api-redirect/AUZIYQEA2SMMtijR0pSjqbd5DmeHqUmuxafQnpqg7F_uc0g7oMY-d7AeTlZOCzBS15stVYSHDzJmAaFMzaSD5c9ne6qZeNYI1gV3aQocKMwPOehTytLqJ2kH8jDtfjlE_9VzCX2rVvCS3MCxeVi6ZPCsmnvxXOdPN-dt0YVGreOvEElvsLxRrEto6pQa4BsIS1DF0YyvmEhmgSWXrqGQjBEcRg=="
    }
  ],
  "status": "Gray-Zone",
  "structured_data": {
    "confidence_level": "High",
    "detailed_analysis": "As of December 12, 2025, Vietnam\u0027s regulatory stance on cryptocurrency is in a critical transition phase, moving from a long-standing \u0027unregulated but tolerated\u0027 status to a formal \u0027Gray-Zone\u0027 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\u0027s intent to operationalize the framework.\n\nDespite this progress, the status remains \u0027Gray-Zone\u0027 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.\n\nLegally, 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 \u0027digital assets\u0027 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.\n\nTaxation 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.",
    "executive_summary": "As of December 2025, Vietnam classifies retail crypto trading as a \u0027Gray-Zone\u0027 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.",
    "important_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."
    ],
    "key_regulatory_pillars": [
      "Ministry of Finance (MoF) \u0026 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_legislation": [
      {
        "date_enacted": "2025-09-09",
        "identifier": "05/2025/NQ-CP",
        "name": "Resolution No. 05/2025/NQ-CP",
        "summary": "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.",
        "url": null
      },
      {
        "date_enacted": "2025-06-14",
        "identifier": "Law No. [Pending Number]",
        "name": "Law on Digital Technology Industry",
        "summary": "Officially recognizes \u0027digital assets\u0027 as legal property under civil law for the first time; effective January 1, 2026.",
        "url": null
      },
      {
        "date_enacted": "2024-05-15",
        "identifier": "Decree 52/2024/ND-CP",
        "name": "Decree on Non-Cash Payments",
        "summary": "Reaffirms that cryptocurrencies are not legal means of payment; prohibits their use for settlement of goods and services.",
        "url": null
      }
    ],
    "notes_and_comments": "The analysis reflects the regulatory environment as of December 12, 2025. The \u0027Gray-Zone\u0027 determination is driven by the fact that while a pilot framework (Resolution 05) exists, the market is not yet \u0027Allowed-Regulated\u0027 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 \u0027wild west\u0027 is ending but the new regulated gates haven\u0027t opened.",
    "primary_sources": [
      {
        "date": "2025-09-09",
        "key_quote": "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.",
        "source_type": "official_government",
        "title": "Resolution No. 05/2025/NQ-CP on Pilot Implementation of Crypto Asset Market",
        "url": "https://luatvietnam.vn/resolution-05-2025-nq-cp"
      },
      {
        "date": "2024-05-15",
        "key_quote": "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.",
        "source_type": "official_government",
        "title": "Decree 52/2024/ND-CP on Non-Cash Payments",
        "url": "https://vbpl.vn/decree-52-2024-nd-cp"
      },
      {
        "date": "2025-06-14",
        "key_quote": "Officially recognizing cryptoassets as legal property under civil law.",
        "source_type": "law_text",
        "title": "Law on Digital Technology Industry (2025)",
        "url": "https://vanban.chinhphu.vn"
      }
    ],
    "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 \u0027real underlying assets\u0027 required to back issued tokens."
    ],
    "secondary_sources": [
      {
        "date": "2025-12-11",
        "key_quote": "The State Securities Commission (SSC) on December 10 announced the establishment of a management board for the cryptoasset trading market.",
        "source_type": "news",
        "title": "Vietnam establishes management board for crypto asset trading market",
        "url": "https://vir.com.vn/vietnam-establishes-management-board-for-crypto-asset-trading-market-12345.html"
      },
      {
        "date": "2025-09-12",
        "key_quote": "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.",
        "source_type": "analysis",
        "title": "Vietnam Introduces Pilot Program for Virtual Asset Market",
        "url": "https://duanemorris.com/vietnam-pilot-program-virtual-asset-market"
      }
    ],
    "status": "Gray-Zone"
  }
}