How Digital Asset Investors in Vietnam Trade Under the New Legal Framework

From the perspective of a crypto investor, Vietnam has entered a completely different phase compared to the era of "high participation but lagging laws." The Government Portal states that Law No. 71/2025/QH15 on the digital technology industry took effect on January 1, 2026. Previously, Government Resolution 05/2025/NQ-CP on piloting a digital asset market had already taken effect on September 9, 2025, with a 5-year pilot period. This indicates that investors are no longer standing in a gray area as before, but are moving into a more structured regulatory framework.

Resolution 05 clearly defines the scope: piloting the offering and issuance of digital assets, organizing digital asset trading markets, providing digital asset services, and related state management mechanisms. This document applies to both Vietnamese and foreign organizations and individuals participating in digital asset investment in Vietnam. The Resolution also defines digital assets as assets represented in the form of digital data, created, issued, stored, transferred, and authenticated by digital technology in an electronic environment. For investors, this is a major milestone as it is the first time the concept of digital assets has appeared in a clear legal structure.

Trading methods have also changed regarding service providers. According to Resolution 05, only organizations licensed by the Ministry of Finance to provide digital asset market organization services are permitted to offer related services and engage in advertising or marketing related to digital assets. Decision 96/QD-BTC dated January 20, 2026, subsequently announced new administrative procedures for the issuance, adjustment, and revocation of licenses; the central authority responsible is the State Securities Commission. In short, investors who want to trade in compliance will have to go through licensed platforms, rather than acting as they did during the largely spontaneous market phase.

Not only is licensing required, but the obligations of service providers are also strictly designed. The Resolution requires service providers to verify the identity of investors opening accounts, manage client funds and digital assets separately from corporate assets, monitor transactions, ensure information technology system security, protect client assets, publicly disclose service fee schedules, and store critical data such as transaction history, wallet addresses, access IPs, and linked bank accounts on servers in Vietnam for at least 10 years. For investors, this means the order placement process may involve a few extra KYC steps, but in return, it offers higher transparency and traceability.

In terms of practical experience, trading digital assets in Vietnam under the new framework can be envisioned as follows: you choose a licensed platform, open an account, verify your identity, link your bank account as required, and understand the fee schedule before trading permitted assets. For foreign investors, Resolution 05 also requires a specialized account mechanism to manage cash flows for buying and selling digital assets in Vietnam. This shows that authorities are moving toward stricter cash flow control and risk management, rather than leaving it unregulated as in the early stages of the market.

Another valuable point is the protection mechanism when a service provider faces legal issues. The Resolution stipulates that if a business has its license revoked, investors have the right to deposit their digital assets with another service provider; if the investor has not yet made a choice, the Ministry of Finance may designate a replacement to complete transactions, contracts, and the asset settlement process for clients, which must be carried out within 45 days. This is a significant difference from the "if the exchange has problems, users are on their own" mentality that was once familiar in crypto.

Market demand is the reason this legal framework is important. Chainalysis reports that Vietnam remained among the leading countries in terms of grassroots crypto adoption in 2025, while Triple-A indicates that Vietnam has one of the highest rates of crypto ownership in the world. PwC, in its December 2025 report, also summarized that crypto in Vietnam is being viewed for exchange and investment purposes, but is not permitted as a means of payment. For investors, this means the current focus remains on trading, custody, and digital asset risk management, rather than using crypto to replace the Dong in daily payments.