Vietnam’s crypto pilot permits up to five licensed providers

Vietnam started its crypto-market pilot in September 2025 and added property, tax and penalty rules in 2026. Bitcoin has meanwhile risen about 40% over 90 days, according to CoinGecko data. The pilot allows at most five licensed providers. No licence announcement was found on the official websites checked on 28 September 2026. This review therefore could not confirm when the six-month period begins. Once it expires, domestic investors face penalties for trading outside providers licensed by the finance ministry.

The market move

Using CoinGecko daily observations through 00:00 UTC on 28 September 2026, bitcoin rose 8.5% over 30 days and 40.4% over 90 days; ether rose 10.0% and 67.0%. At that timestamp, bitcoin remained about 33% below its peak of USD 126,080 on 6 October 2025. No official source reviewed attributes the rise to a policy decision.

What Vietnamese law now recognises

The Law on the Digital Technology Industry, 71/2025, in force since 1 January 2026, treats digital assets as property under the Civil Code. It defines crypto-assets as digital assets authenticated using encryption or equivalent digital technology, excluding securities, digital forms of fiat currency and other financial assets governed by civil and financial law.

The pilot market

Government Resolution 05/2025 started a five-year pilot on 9 September 2025. The Ministry of Finance selects at most five crypto-asset service providers, licensed to operate trading markets and provide related services. Each needs paid-in capital of at least 10,000 billion dong contributed in dong, and foreign investors may hold no more than 49% of it. Offering, trading and payment must be in dong. New crypto-assets issued under the pilot may be offered only to foreign investors.

The ministry began accepting licence applications on 20 January 2026, the Government portal reported, and in May it said it expected the market to start operating from the third quarter of 2026. No licence announcement was found on the websites of the State Securities Commission, the Ministry of Finance or the Government portal checked on 28 September. On 15 September the commission published a draft circular on reporting and disclosure for the crypto-asset market.

The six-month deadline and the fines

Vietnamese investors already holding crypto-assets may open accounts with providers licensed by Vietnam’s Ministry of Finance. Six months after the first provider is licensed, domestic investors who trade outside licensed providers face administrative penalties or criminal liability, depending on the nature of the breach. The resolution defines a domestic investor as an individual with Vietnamese nationality or an organisation established under Vietnamese law.

Decree 284/2026, in force since 1 September 2026, sets the fine for that breach at 30 million to 50 million dong for organisations. Individuals pay half, 15 million to 25 million dong. Separately, domestic investors trading crypto-assets that may be offered only to foreign investors face fines of 35 million to 50 million dong for individuals and 70 million to 100 million dong for organisations. That provision is not tied to the six-month period.

Tax

Under Circular 32/2026, in force since 27 March 2026, individuals transferring crypto-assets pay 0.1% of each transfer price whether or not they are tax resident, the Ministry of Finance said. The personal income tax law, 109/2025, in force since 1 July 2026, lists income from transferring digital assets and sets the same 0.1% rate for resident individuals.

Cross-border reporting

The OECD’s list of commitments to its Crypto-Asset Reporting Framework, updated on 14 September 2026, names Vietnam among four jurisdictions identified as relevant that have not yet committed. Under domestic CARF rules, covered providers report user and transaction information to the relevant tax authority for exchange with eligible partner jurisdictions. The OECD lists 46 jurisdictions, including Portugal, Malta and Greece, as committed to first exchanges by 2027; 27, including Singapore, Hong Kong, the United Arab Emirates, Thailand and Malaysia, by 2028; and four, including the United States, by 2029. Its guidance envisages collection generally beginning a year before first exchanges. Separately, DAC8, the EU directive extending tax cooperation to crypto-asset reporting, required member states to apply its main implementing provisions from 1 January 2026.

What it means for cross-border capital

Once providers are licensed, foreign investors’ money is to move through a single account. Under the resolution, each foreign investor must open one dong payment account at a bank licensed for foreign-exchange services, funded by selling foreign currency to an authorised bank or from the investor’s own dong account at an authorised bank; money from the lawful receipts listed in that article may be converted back into foreign currency at an authorised bank and remitted abroad. The bank is to report the account’s flows each quarter to the Ministry of Finance, the Ministry of Public Security and the State Bank. New crypto-assets issued under the pilot may be offered only to foreign investors and traded only among them through licensed providers. The line is nationality, not residence: foreign nationals and foreign-law entities qualify, while Vietnamese nationals do not, wherever they live; the texts reviewed do not address dual nationals. On tax reporting, Vietnam has not yet committed to the OECD framework that 77 jurisdictions have committed to implement, with first exchanges due between 2027 and 2029; unlike India, it is not footnoted as preparing a commitment.

For Vietnamese families

Because the definition turns on nationality, a Vietnamese national living abroad is a domestic investor under the resolution. How the six-month rule would apply to trading on a foreign platform from abroad is not set out in the texts reviewed. For a family becoming tax resident in Portugal, gains outside business activity on crypto-assets that are not securities and have been held for at least 365 days may qualify for exclusion from tax. The tax authority’s guidance limits this to transactions between residents of the EU, the European Economic Area or jurisdictions covered by Portuguese tax or information-exchange agreements. Otherwise, taxable gains on these assets generally face a 28% rate, or the ordinary income-tax rates if the taxpayer chooses to combine them with other income.