You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

April 28, 2025

Vietnam’s Emerging Regulatory Landscape for Blockchain and Cryptocurrency

Subscribe to Updates

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.

Related Professionals

Industries

Fintech

Technology

Practices

Banking and Finance

Location

RELATED INSIGHTS​ 

May 14, 2025
Following the amendment to the Emergency Decree on Measures for the Prevention and Suppression of Technological Crimes in mid-April 2025, new measures were introduced by the Electronic Transactions Development Agency (ETDA) in a hearing session held on May 13, 2025, to establish shared liability between online social media platform operators and other in-scope operators for damages arising from technological crimes. Stakeholders are being invited to submit their comments on the proposed new provisions directly to the ETDA by May 20, 2025. The concept of the new measures for social media platform operators is that to be released from liability for damages arising from technological crimes, social media platform operators must demonstrate compliance with the relevant technological crime prevention standards and measures prescribed by their respective regulators (“safe harbor rules”). Safe Harbor Rules Under the principles of the proposed safe harbor rules, social media platform operators and the relevant service providers would be required to comply with the following obligations: Immediate takedown and suspension of dissemination: Disable access, remove the content from the system, or suspend the relevant service within 24 hours of receiving an official notification from the Cyber Crime Investigation Bureau’s Anti-Online Scam Operation Center (AOC) that a service or social media platform is disseminating content that is or may be used to commit or support technological crimes. Establishment of notification channels: Establish a system or channel to receive notifications from the AOC. User registration and identity verification: Require user registration (including identity verification and authentication) before allowing content to be posted, with sufficient information to identify the user. Suspending dissemination of suspect advertisements: Disable access to advertisements reasonably suspected of involving or potentially involving the commission of technology-related crimes. Reporting: Report on actions taken, including details like account owner information, IP address, email, or phone number used for account
Read More
May 5, 2025
On April 29, 2025, the government of Vietnam promulgated Decree No. 94/2025/ND-CP with regulations on a controlled “sandbox” for innovative fintech solutions in the banking sector (Decree 94). The decree aims to promote innovation, modernize banking, and enhance financial inclusion while assessing risks and benefits of fintech solutions in a controlled testing environment. Fintech Sandbox Currently, the fintech sandbox focuses on three specific areas: Credit scoring Open API data sharing Peer-to-peer (P2P) lending Eligible participants for the fintech sandbox include: Credit institutions and foreign bank branches (except for P2P lending) Fintech companies operating in Vietnam Cross-border supply by foreign providers is not included in the sandbox framework. Eligible participants are permitted to provide fintech solutions only within the scope specified in the Certificate of Sandbox Participation issued by the State Bank of Vietnam in consultation with other ministries. P2P lending companies face specific restrictions within the fintech sandbox, including prohibitions against: Providing security for customer loans Operating as a customer (i.e., P2P lender or borrower) Providing P2P lending solutions to pawn shops The maximum sandbox period is two years, with the possibility of extension as permitted by law. The outcomes of the fintech sandbox will serve as a practical basis for authorities to develop and refine future fintech regulations. It is worth noting that participation in the sandbox does not guarantee that participants will meet relevant business and investment conditions that may be stipulated in future regulations. Decree 94 will take effect on July 1, 2025, signaling that the Vietnamese government intends to take a proactive approach to fostering fintech development. Implications Parties interested in participating in the fintech sandbox should begin preparing now to be ready to apply for a Certificate of Sandbox Participation when the decree takes effect.
Read More
May 2, 2025
Attorneys from Tilleke & Gibbins have updated the latest edition of Doing Business in Thailand, a Q&A-style guide from Thomson Reuters Practical Law that offers an overview of key legal considerations for companies operating in jurisdictions worldwide. The contribution outlines the country’s legal and regulatory framework for foreign investment and business operations and reflects the latest legislative developments. The chapter addresses the following core topics: Legal system: Structure of the courts and the codified nature of Thai law. Foreign investment: Business restrictions under the Foreign Business Act, sector-specific regulations, exchange control rules, and investment incentives. Business vehicles: Overview of partnerships, private and public limited companies, and other legal entities. Employment: Labor protections, employment contracts, foreign worker requirements, and termination procedures. Tax: Corporate and personal income tax, indirect taxes, and tax obligations for residents and non-residents. Intellectual property: Registration and enforcement of patents, trademarks, designs, and copyrights. Data protection: Key provisions of the Personal Data Protection Act and related compliance obligations. Competition law: Regulatory framework under the Trade Competition Act. Anti-bribery and corruption: Relevant legislation and enforcement mechanisms. E-commerce and digital business: Legal regime for online transactions and digital platforms. Marketing and advertising: Consumer protection laws and regulations affecting advertising and marketing practices. Product regulation and liability: Safety standards, liability regimes, and roles of enforcement authorities. Practical Law, a legal reference resource from Thomson Reuters, publishes a range of guides for hundreds of jurisdictions and practice areas. The insurance and reinsurance guide is a valuable resource for legal practitioners, covering numerous jurisdictions worldwide. To view the latest version of the guide, please visit the Practical Law website and enroll in the free Practical Law trial to gain full access.
Read More
April 30, 2025
With a favorable crypto climate from the Trump administration in the United States, Thailand is ready for digital asset platforms and has market appetite. This article highlights the country’s regulatory initiatives supporting the growth of digital assets like crypto, stablecoins, and smart contracts, along with efforts to establish clear oversight. Bank of Thailand Sandbox Stablecoins used as a medium of payment, particularly those pegged to the Thai baht (THB) for public use, are considered as mirroring fiat currency, which violates the Currency Act B.E. 2501 (1958). These can also be classified as e-money under the Payment Systems Act B.E. 2560 (2017). The Bank of Thailand (BOT) urges issuers to engage in preconsultation prior to implementation, due to concerns about stablecoins being used in place of THB currency. Other FX- or asset-backed stablecoins are not recognized as legal tender under Thai law, and users must bear their own risks. The BOT recognizes the potential and benefits of these technologies in reducing operational costs for financial service providers and addressing the needs of financial service users. Consequently, the BOT issued a sandbox framework in June 2024. In particular, the enhanced regulatory sandbox allows nonlicensed entities to test financial innovations in controlled conditions. These tests must have a clearly defined duration (usually under one year) and involve a limited user group with an exit strategy. Several programmable payment projects—automated transactions with predefined conditions for the payment of goods and services—were piloted under this sandbox, which closed for applications in September 2024. Eight participants are planning to launch their test runs this year, some of which include asset tokenization or exchange global stablecoins in their programmable payment projects. Thai Securities and Exchange Commission Sandbox Given that digital asset businesses fall under the Royal Decree on Digital Asset Businesses B.E. 2561 (2018), supervised by
Read More