Vietnam's ambitious plan to regulate its burgeoning cryptocurrency market has hit an unexpected snag: no companies have yet applied for licenses to operate under the new pilot program, despite its immediate commencement in September 2025. This reluctance stems primarily from the exceedingly high barriers to entry established by the Vietnamese government, designed to ensure a tightly controlled and cautious approach to digital assets.
The five-year pilot program, formalized under Resolution 05/2025/NQ-CP, aims to create a national framework for trading digital assets in a regulated environment. The framework was introduced to bring the previously unregulated crypto market under official supervision. Despite the lack of a legal framework, the cryptocurrency market in Vietnam has thrived, with millions of citizens holding digital assets. The government's intention is to co-opt, control, and capitalize on this sprawling market, which has flourished beyond its regulatory grasp.
However, the stringent rules are deterring potential applicants. A key obstacle is the minimum capital requirement of 10 trillion Vietnamese dong (approximately $379 million USD) for any company seeking to run a crypto exchange. Furthermore, at least 65% of this capital must be held by organizations, with over 35% coming from at least two institutional investors, such as commercial banks, securities companies, or insurance firms. This effectively sidelines smaller startups and favors large, state-linked institutions.
Adding to the restrictive nature of the pilot, only enterprises incorporated under Vietnamese law are eligible to apply for operator licenses. Foreign investors can participate, but their ownership is capped at 49% of any platform. Moreover, the pilot program mandates that all transactions, including issuance, trading, and payments, be conducted in Vietnamese dong. The issuance of crypto assets is restricted to Vietnamese firms, and these assets can only be offered to foreign investors. The program also prohibits the issuance of crypto assets backed by fiat currencies or securities; instead, they must be backed by real assets.
Despite these challenges, the Ministry of Finance (MoF) is proceeding with the implementation plan. The MoF has been drafting detailed regulations for pilot operations, including taxation, fees, and accounting policies, and has assigned specialized units to develop licensing procedures. The State Securities Commission (SSC) is currently reviewing guiding documents related to licensing, including criteria sets and regulations for providing crypto asset services. The ministry is also coordinating with the State Bank of Vietnam and other ministries to finalize the framework.
Deputy Minister Nguyen Duc Chi acknowledged at a government press briefing on October 5, 2025, that the MoF has not yet received any official proposals from enterprises to join the crypto asset market. However, he noted that some businesses have engaged in technical discussions with ministry officials regarding IT systems, staff capacity, capital requirements, and operational procedures. The MoF hopes to license at least one enterprise before 2026, depending on the readiness of businesses. While the ministry anticipates interest from numerous businesses, it intends to license a maximum of five enterprises for the pilot crypto asset exchange.
The Vietnamese government's cautious approach reflects concerns about capital flight, tax evasion, and money laundering, amplified by its inclusion on the Financial Action Task Force (FATF) "grey list". By establishing high barriers to entry and strict controls, Vietnam aims to mitigate these risks while fostering a digital economy. However, the lack of applicants so far suggests that the current framework may be too restrictive to attract significant participation. The government may need to re-evaluate its approach to strike a balance between control and innovation in the crypto market.
