Vietnam has a specific pilot framework for the crypto-asset market under Resolution No. 05/2025/NQ-CP of 9 September 2025. The Ministry of Finance introduced licensing procedures for crypto-asset trading-platform services, with applications accepted from 20 January 2026. Entry is restricted to applicants meeting the pilot’s conditions; ordinary incorporation or an offshore licence does not replace the required Vietnamese permission. Other crypto-related models still require activity-specific legal analysis.
Market entry requires activity-by-activity legal analysis.
Regulatory risk is higher than in fully licensed jurisdictions.
Prepared by RUE editorial team · Updated 12 May 2026
Request a legal assessmentVietnam has a specific pilot framework for the crypto-asset market under Resolution No. 05/2025/NQ-CP of 9 September 2025. The Ministry of Finance introduced licensing procedures for crypto-asset trading-platform services, with applications accepted from 20 January 2026. Entry is restricted to applicants meeting the pilot’s conditions; ordinary incorporation or an offshore licence does not replace the required Vietnamese permission. Other crypto-related models still require activity-specific legal analysis.
RUE approaches Vietnam as a regulatory-structuring jurisdiction, not as a plug-and-play licensing jurisdiction. That distinction matters for founders building exchanges, custodial products, broker apps, token platforms, OTC desks, mining-related services or crypto-linked payment flows.
RUE helps founders define the real regulatory perimeter, structure Vietnam-facing operations, review token and payment logic, prepare legal documentation, and align local setup with offshore licensing strategy where needed.
The term crypto license in Vietnam is commercially used, but in legal practice the analysis starts with whether the activity is even licensable, restricted, or indirectly captured by adjacent financial rules.
Custody, exchange matching, brokerage, wallet control, fiat ramps, token issuance and payment functionality create different risk profiles and may trigger different regulatory concerns.
If a token model or platform function starts resembling a means of payment, the legal risk rises materially. That point must be tested before launch, fundraising or marketing.
Many Vietnam-facing projects separate local commercial operations from offshore regulated functions such as custody, exchange execution or token issuance governance.
The main requirement in Vietnam is correct legal qualification of the activity before launch. Because there is no universally available standalone crypto license for all business models, founders must build the project around the applicable corporate, contractual, AML, tax, data, cybersecurity and consumer-facing rules.
A legally workable structure usually requires a combination of entity setup, internal controls, restricted activity analysis, banking review and terms-of-service alignment. The regulator will look less at branding and more at what the platform actually does: who controls wallets, who receives fiat, who executes transfers, who markets returns, and who bears customer-facing responsibility.
The company must define whether it provides exchange, custody, brokerage, software, token issuance support, mining support, analytics or payment-linked services. Legal analysis starts from function, not marketing language.
A local company may be needed for staffing, contracting, invoicing, marketing or technology operations, but some regulated-risk functions may need to remain outside Vietnam depending on the model.
If the product enables settlement, stored value, redemption logic or merchant-style payment use, the project requires enhanced legal review. Payment-like features are a primary regulatory red flag.
Even where no standalone crypto authorization exists, a serious operator should maintain KYC, risk scoring, sanctions screening, transaction monitoring, escalation and recordkeeping controls. Banking partners typically expect this baseline.
Website claims, risk warnings, custody disclosures, fee terms, complaint handling and jurisdiction clauses must match the actual operating model. Misalignment between public claims and legal structure is a frequent failure point.
Wallet security, access control, incident response, logging, outsourcing oversight and personal data handling should be documented from day one. This is not cosmetic; it is part of launch readiness.
Compare Vietnam with other jurisdictions by the applicable regulatory framework, permitted activities, review period, fees, capital, local substance and cross-border permissions. Local registration or authorisation is distinct from EU MiCA/CASP authorisation and does not grant EU passporting.
6 jurisdictions in this table
* This table focuses on MiCA/CASP authorization conditions. Use the settings icon to customize countries and parameters.
Tax treatment for a crypto business in Vietnam depends on the legal form, revenue model, customer location and transaction characterization. There is no safe blanket statement such as “crypto is tax free” or “crypto is taxed like securities” that can be applied across all models.
Founders should separate at least four layers: corporate income taxation, indirect tax exposure, withholding on cross-border payments, and bookkeeping treatment of digital assets, fees and treasury positions. A platform earning spread, commissions, listing fees, software subscriptions or treasury gains may face different accounting outcomes even within one group structure.
For Vietnam-facing operations, tax review should be completed together with legal scoping and banking setup. RUE typically aligns this work with accounting structuring and, where relevant, cross-border payment flows.
Vietnam has a specific pilot framework for the crypto-asset market under Resolution No. 05/2025/NQ-CP of 9 September 2025. The Ministry of Finance introduced licensing procedures for crypto-asset trading-platform services, with applications accepted from 20 January 2026. Entry is restricted to applicants meeting the pilot’s conditions; ordinary incorporation or an offshore licence does not replace the required Vietnamese permission. Other crypto-related models still require activity-specific legal analysis.
Answer a few quick questions to find out if this jurisdiction suits your crypto business
Based on your answers, this jurisdiction matches your business requirements well. Here's a quick summary:
Recommended License
CASP License
Estimated Budget
€24,000 – €35,000
Estimated Timeframe
4–6 months
EU Passporting
Available
We identify the real activity: exchange, custody, brokerage, token issuance, software, payments adjacency or mixed model. The first output is a legal risk map, not a generic checklist.
We test whether the business can operate through a Vietnam entity, requires a split structure, or should keep higher-risk functions in another jurisdiction.
We prepare the corporate architecture, service agreements, customer documents, disclosures and internal allocation of functions between local and offshore entities.
We assemble AML, sanctions, onboarding, custody, security, outsourcing and incident-response documentation proportionate to the actual model.
We align the structure with account opening, payment provider expectations, source-of-funds evidence and transaction narrative before commercial launch.
We review website claims, onboarding flows, policy implementation and change triggers so the live business remains within the intended legal perimeter.
Open the key issues founders, compliance teams and legal leads usually need to confirm before launch.
There is no simple universal standalone crypto license that covers all crypto business models in Vietnam. The legal answer depends on the exact activity, especially whether the project involves custody, exchange execution, fiat movement, token issuance or payment-like functionality.
A crypto exchange model requires detailed legal review before launch. Exchange activity raises the highest level of regulatory sensitivity because it may involve customer asset control, settlement, AML exposure and banking risk. The structure should be tested before any public rollout.
Yes, but only if the model is genuinely non-custodial in substance. If the operator can route, approve, recover or practically control transactions, the platform may still be viewed as exercising meaningful control despite non-custodial branding.
The main legal fault line is payment functionality. If a token, wallet or platform feature starts functioning like a means of payment, settlement tool or stored-value mechanism, the risk profile increases materially and the project may become commercially unworkable without restructuring.
Not always, but many projects need a local entity for commercial, staffing or contracting reasons. The correct answer depends on where the risky functions sit, who contracts with users, who receives funds and how the service is marketed in Vietnam.
Foreign participation is possible in many structures, but ownership alone does not solve the regulatory analysis. The more important issues are business scope, function allocation, licensing exposure, banking acceptance and compliance readiness.
The first documents should be the product scope memo, asset-flow map, corporate structure chart and draft customer-facing materials. These documents usually reveal whether the project is software-led, custody-led, exchange-led or payment-sensitive.
Vietnam has a specific pilot framework for the crypto-asset market under Resolution No. 05/2025/NQ-CP of 9 September 2025. The Ministry of Finance introduced licensing procedures for crypto-asset trading-platform services, with applications accepted from 20 January 2026. Entry is restricted to applicants meeting the pilot’s conditions; ordinary incorporation or an offshore licence does not replace the required Vietnamese permission. Other crypto-related models still require activity-specific legal analysis.
Yes, in practice a serious operator should implement AML and sanctions controls from the start. This is essential for banking, investor diligence, audit readiness and defensible risk management, especially for custody, exchange and brokerage models.
No. Vietnam may be relevant for regional operations or market strategy, but it is not a substitute for EU authorization under MiCA. A business seeking regulated access to the EU market should separately assess a CASP structure or a jurisdiction-specific MiCA licensing route.
