Vietnam’s crypto asset market remains in its early, pilot stage. As such, during the five-year pilot period, the framework will be continually reviewed and fine-tuned to ensure it operates in line with market developments. Experts believe that if the implementation of Resolution No. 05/2025/NQ-CP on the pilot rollout of the crypto asset market in Vietnam delivers positive outcomes and receives strong social acceptance, a standalone law on crypto assets could be developed.
Sharing insights into the process of drafting Resolution No. 05, Ms. Le Thi Hoang Thanh, Deputy Director General of the Department of Economic-Civil Legislation at the Ministry of Justice (MoJ), said the issue of legally institutionalizing crypto assets had been raised as early as ten years ago and had undergone extensive debate. These discussions focused on three core questions: whether crypto assets should be recognized as assets; which legal instrument should be used and whether the Civil Code would need to be amended; and which ministry should assume primary responsibility. After extensive inter-ministerial discussions, consensus was eventually reached, Ms. Thanh said.
Regulatory rollout
Accordingly, crypto assets were recognized as assets, as they possess all essential attributes of assets, including being the result of labor, production, and investment, having identifiable value, and being capable of existing as physical assets or property rights depending on their structure. It was also agreed that the Civil Code, as the foundational law, should remain unchanged, as it is designed to regulate only stable and general social relations.
Both the Ministry of Finance (MoF) and the MoJ supported issuing a dedicated regulatory instrument tailored to this special class of assets. Regarding institutional responsibility, the MoF was designated as the lead agency, given the financial nature of crypto assets and their role in capital mobilization.
According to Mr. To Tran Hoa, Standing Deputy Head of the Management Board for the Digital Asset Trading Market at the State Securities Commission (SSC) under the MoF, Article 17 of Resolution No. 05 assigns several key tasks to the Ministry. First is the drafting of a decree on administrative sanctions in the crypto asset sector, which has already been submitted to the government for promulgation.
Second, the resolution requires the MoF to coordinate with other ministries to provide detailed guidance on its implementation. Two major issues are currently being addressed: accounting and auditing regimes for enterprises participating in the crypto asset market, and tax regimes applicable to crypto asset-related activities.
Mr. Hoa said the Ministry is drafting three circulars: one on accounting and auditing regimes for crypto asset service providers, issuers, and trading enterprises; one on tax policy, setting out a framework for applicable tax rates; and one defining taxable entities and providing guidance on tax collection. “The SSC is coordinating with relevant units under the Ministry, and these circulars are expected to be issued in the first quarter of 2026,” he said.
In parallel, the SSC has submitted proposals for ministerial-level decisions, including a decision issuing an implementation plan for Resolution No. 05, which establishes professional focal points to support market operations.
In addition, the Commission has submitted Decision No. 96 on administrative procedures to the MoF for issuance. On January 20, it officially opened the portal to receive the first registration applications from organizations seeking to provide crypto asset services.
Ms. Nguyen Van Hien, Vice Chairwoman and Secretary General of the Vietnam Blockchain and Digital Assets Association, said a series of legal frameworks had been issued during 2024-2025 to accelerate market development. “We often joke that just over one year of policy-making has achieved what would normally take ten years to build,” she said.
While Vietnam entered the field later than some countries, Ms. Hien noted that it has actively learned from and adapted international regulatory models. As a result, Vietnam is not moving slowly but rather at a relatively fast pace, with basic legal frameworks already in place. She expressed an expectation that more specialized and in-depth regulations would follow.
From a legislative perspective, Mr. Nguyen Hai Nam, Standing Member of the National Assembly’s Economic and Financial Committee, said Vietnam’s approach reflects two key realities: its relatively large volume of crypto asset transactions compared to global markets, and its strong pool of information technology engineers. These factors, he said, underscore the sector’s development potential.
He added that the Law on Digital Technology Industry, passed in June 2025 and effective from January 1, 2026, includes provisions on digital assets under the Civil Code, signaling a gradual legal formalization of real-economy developments. In addition, pressure from international organizations such as the Financial Action Task Force to strengthen anti-money laundering and counter-terrorist financing measures has reinforced the government’s resolve. Resolution No. 05 was issued just three months after the Law’s passage. “The approach is gradual, proactive, and cautious, ensuring development while maintaining legislative discipline, system security, and investor protection,” Mr. Nam said.
Towards a dedicated law
Experts emphasized that current legalization efforts do not amount to the immediate and full legitimization of the crypto asset market, but rather the establishment of a foundational framework for future growth. Once such a framework is in place, key questions will include how Vietnam identifies and channels global capital flows, estimated at more than $220 billion, how transactions are structured, and how many Vietnamese currently hold crypto assets.
Under Resolution No. 05, crypto asset exchanges operating during the pilot phase will serve two groups: Vietnamese investors currently trading on overseas platforms, and foreign investors, particularly those interested in crypto assets linked to real-world assets; a segment forecast to grow strongly through 2030.
Ms. Hien said a robust legal framework would enhance transparency and investor confidence. After the pilot phase, crypto assets could become accessible to both international and domestic investors, creating opportunities to attract new capital into Vietnam. “We expect the initial legal framework to continue evolving, with the crypto asset market potentially developing in parallel with the stock market,” she said.
Ms. Thanh noted that sufficient grounds already exist to move beyond Resolution No. 05, which has a five-year validity period. Depending on implementation outcomes, higher-level legal instruments could be considered even before the pilot period concludes.
She outlined three possible paths: issuing a decree to guide implementation of the Law on Digital Technology Industry, continuing with a National Assembly pilot resolution at a higher legal level, or, ideally, enacting a standalone law on crypto assets. “The choice will depend on implementation effectiveness and social demand,” Ms. Thanh said. “If Resolution No. 05 delivers positive results and broad social acceptance, a dedicated law on crypto assets would be appropriate, one that balances effective management with the promotion of market development.”
Mr. Nam added that international practice typically progresses from framework laws to pilot sandboxes and eventually to specialized legislation. Vietnam is currently in the second phase, requiring time for implementation, supervision, and evaluation. Once data is sufficiently mature, policymakers can determine the appropriate timing for a specialized law, aligned with Vietnam’s broader economic context.
