While Vietnam has yet to issue its first crypto exchange license, there are indications of progress with five companies successfully completing an initial assessment within the country’s digital asset market pilot program.
Summary
- No crypto exchanges are currently licensed in Vietnam, but five applicants have passed the initial review stage.
- Each applicant must demonstrate at least 10 trillion Vietnamese dong (approximately $383 million) in charter capital along with Level 4 security certification for their information systems.
- Effective September 1, Decree 284 outlines penalties for violations within the crypto market pilot program.
- A transitional period of six months will apply for domestic traders before fines can be enforced for using unlicensed offshore platforms.
- The official licensing process will commence with the Ministry of Finance’s first license approval.
During the Vietnam RWA Summit 2026, To Tran Hoa, deputy head of the Digital Asset Trading Market Board at the State Securities Commission of Vietnam, reported on the advancements in the licensing process. However, the authorities have not disclosed the identities of the five applicants or the timeline for final licensing decisions, emphasizing that passing the initial assessment does not equate to the authorization for operation as an exchange.
Financial Requirements for Crypto Exchange Applicants
Under Vietnam’s Resolution No. 05/2025/NQ-CP, applicants seeking to establish a crypto exchange must present a substantial charter capital of at least 10 trillion Vietnamese dong, which is about $383 million. This capital must primarily be contributed in Vietnamese dong and consists of several stipulations:
- At least 65% of this capital should come from institutional shareholders.
- A minimum of 35% must be contributed by at least two accredited organizations, which can include banks, securities companies, fund managers, insurers, or tech firms.
Furthermore, a security appraisal confirming the adequacy of the technology to meet Level 4 information-system security standards is required, with assessments conducted by the Ministry of Public Security prior to operational commencement. Other regulations demand compliance with management qualifications, custody measures, transaction monitoring, and internal control systems aimed at anti-money laundering and customer identification verification.
Implementation of New Penalties from September 1
Decree No. 284/2026/ND-CP, set to take effect on September 1, enforces new penalties for various infractions in the crypto market. This decree holds implications for unlicensed operations, improper token issuance, insufficient customer verification, and failures in anti-money laundering measures. Specific fines include:
- Organizations providing crypto services without a license may face fines of 180 million to 200 million dong.
- Unauthorized platforms risk having their associated websites and systems removed.
- Licensed service providers can incur penalties for inadequate separation of customer assets and failure to monitor transactions, along with fines ranging from 50 million to 70 million dong for customer verification lapses.
For individuals committing violations, fines are typically half of those applied to organizations, capped at 100 million dong for individuals.
Transition for Domestic Traders Regarding Platform Usage
Article 9 of the new decree stipulates penalties ranging from 30 million to 50 million dong for domestic investors engaging with platforms not licensed by the Ministry of Finance. However, these fines are not immediate; they will only apply six months following the licensing of the first crypto asset service provider. As no licenses have yet been issued, this transition period has not begun, allowing domestic investors to continue trading on unlicensed platforms without facing penalties at this time.
Despite this grace period, other violations outlined in Decree 284 will still be enforceable from September 1, encompassing the operation of unauthorized platforms and errors in customer data management.
The Countdown to Licensing and Its Implications
Launched through Resolution 05 on September 9, 2025, Vietnam’s pilot program aims to structure a regulated environment for the crypto market, dictating rules on issuance, custody, trading, and licensing. Under this framework, locally issued crypto assets can only be marketed to foreign investors, with eligibility contingent upon the backing of tangible assets without representing fiat currencies or securities.
While the regulatory authorities previously indicated that only a limited number of exchanges would be granted licenses, the current status of the five assessment-approved applicants does not guarantee their eventual licensing. The first license issued by the Ministry of Finance will initiate the six-month countdown during which domestic investors will be required to conduct all crypto trading through sanctioned platforms. Until such a deadline is established, investors are advised to closely monitor updates from the Ministry and the State Securities Commission rather than interpreting initial assessments as operational rights.
