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April 28, 2025

Vietnam’s Emerging Regulatory Landscape for Blockchain and Cryptocurrency

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In recent years, Vietnam has positioned itself among the leading countries in the world in terms of digital asset ownership and trading volume. This rapid adoption reflects the country’s growing digital economy and the increasing engagement of individuals and businesses in blockchain-based financial activities.

Central to this growth are Resolution No. 57-NQ/TW of the Politburo dated December 22, 2024, on breakthroughs in science, technology, innovation, and national digital transformation with a vision to 2045 (“Resolution 57”) and Resolution No. 03/NQ-CP of the Government dated January 9, 2025, promulgating the Action Plan to Implement Resolution 57 (“Resolution 03”), which outline a flexible and innovative policy framework that embraces pilot programs for emerging technologies to lay the groundwork for Vietnam’s legislative framework concerning cryptocurrency and blockchain technologies.

Regulatory clarity in terms of digital assets and blockchain technologies is now more critical than ever for businesses and investors. In light of this, Vietnam is currently in the process of introducing three key legal instruments, with drafts of the Law on Digital Technology Industry (“Draft DTI Law”), Resolution of the National Assembly on the Establishment of Regional and International Financial Centers in Vietnam (“Draft Financial Center Resolution”), and Resolution of the Government on the Pilot Implementation of Crypto Asset Markets in Vietnam (“Draft Crypto Pilot Resolution”) nearing promulgation.

Current Regulatory Direction and Schedule

Vietnam’s regulatory framework for crypto assets and blockchain has been in a developmental stage since 2017, focusing on directions, plans, and schedules rather than established regulations.

In February 2024, under Decision No. 194/QD-TTg of the Prime Minister, the Ministry of Finance (MOF) was assigned to draft a legal framework to either prohibit or regulate virtual assets and service providers by May 2025, signaling a clearer regulatory direction. In March 2025, Directive No. 05/CT-TTg of the Prime Minister directed the MOF and the State Bank of Vietnam (SBV) to propose a legal framework for managing and promoting the healthy and effective development of digital assets and currencies within March 2025. It can be seen that Vietnam’s regulatory position is taking shape and will soon play a crucial role in determining Vietnam’s crypto asset and blockchain environment.

Upcoming Legislation

1. Draft DTI Law

Initiated in 2024, the Draft DTI Law is expected to be the first law-level document to establish a binding regulatory framework for cryptocurrency and blockchain. Particularly, with the latest version of the draft, the first-ever definition of digital assets (covering virtual assets in an electronic environment and crypto assets) is introduced. While the proposed regulations have yet to explicitly qualify cryptocurrency as a digital asset, based on the current definition under the Draft DTI Law, digital assets may be broadly interpreted to cover cryptocurrency. Based on the groundwork laid by the official DTI Law, tax issues pertaining to cryptocurrency and crypto-related businesses may be addressed in the near future.

The Draft DTI Law also provides the definition of blockchain technologies, and recognizes blockchain technologies as one of the strategic digital technologies for which development should be prioritized and included in the Digital Technology Industry Development Program – a program approved by the prime minister every five years to boost development.

The Draft DTI Law introduces a controlled sandbox for digital technology convergence products and services, either unregulated or regulated differently from existing regulations, within specific limits of space, time, scale, and pilot subjects. Of note, digital technology convergence is defined broadly and might arguably encompass cryptocurrency and blockchain-related products and services, which could therefore be eligible for the pilot mechanism, providing a pathway to support and regulate their development in Vietnam

It is anticipated that the DTI Law will be passed soon, as it will be discussed for promulgation in the National Assembly’s 9th Session in May 2025.

2. Draft Financial Center Resolution

An updated version of the Draft Financial Center Resolution (see our previous article), known as the 19th version, has been released to the public. This version allows members of the international financial centers to establish transaction floors/platforms in the respective financial centers for conducting digital asset transactions. The Draft Financial Center Resolution also sets forth organizational and operational principles; management and monitoring mechanisms, and incentive policies for these transaction floors/platforms.

The Draft Financial Center Resolution also provides regulations on the controlled sandbox mechanism for fintech and innovation within a determined timeframe, applicable to technologies, products, services, and business models that have yet to be regulated in Vietnam.

There appear to be two controlled sandboxes, one under the Draft Financial Center Resolution (by the MOF) and one under the Draft DTI Law (by the Ministry of Science and Technology), both concerning digital assets and likely overlapping. We are awaiting further developments to see how this issue will be addressed.

The Draft Financial Center Resolution is also expected to be reviewed and approved by the National Assembly during their 9th Session in May 2025 under the accelerated program.

3. Draft Crypto Pilot Resolution

On the basis of Official Telegram No. 22/CD-TTg of the Prime Minister dated March 9, 2025, and Notification No. 81/TB-VPCP of the Government Office dated March 6, 2025, the MOF has proposed a Draft Resolution on Pilot Implementation of Crypto Assets in Vietnam, proposing a pilot program for the management, issuance, trading, and ownership of crypto assets in Vietnam’s crypto asset market. The pilot program will last from the effective date of the official Crypto Pilot Resolution until December 31, 2027. Based on the assessment and summaries of practical implementation of the pilot program, the government will consider the organization and operation of the crypto asset market in Vietnam.

The Draft Crypto Pilot Resolution introduces some critical definitions for crypto-related businesses, including definitions of crypto assets, stable crypto assets, crypto asset service providers, and other terms. Particularly, crypto asset service providers are defined as enterprises that are duly licensed by the MOF to implement or provide the following services: (i) organization of crypto asset transaction/trading markets; (ii) proprietary trading of crypto assets; (iii) custody of crypto assets; and (iv) provision of platforms for crypto asset issuance.

The Draft Crypto Pilot Resolution also includes a coordination mechanism among the MOF, the SBV, the Ministry of Public Security, and the Ministry of Science and Technology with the dual objectives of promoting market activities and minimizing financial security risks to ensure stability in the financial and monetary system.

Outlook

The long-awaited introduction of this legislation marks a pivotal moment for the cryptocurrency and blockchain landscape in Vietnam, as it not only signals stronger legal clarity but also opens the door for new business opportunities in the market.

Now that this area is beginning to take legislative shape for the first time, it is expected to have a significant impact on other existing legal frameworks, notably the Civil Code, information security and data privacy, trading conditions in cyberspace, taxation, anti-money laundering, counter-terrorist financing, anti-corruption, and more. Stakeholders should therefore closely monitor the upcoming developments to ensure timely compliance, seize emerging opportunities, and stay ahead in this rapidly evolving market.

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