Vietnam Sets VND 10 Trillion Capital Bar for Crypto Exchange Operators
Vietnam's National Assembly passed the Law on Digital Technology Industry in June 2025, creating the country's first legal framework for digital assets. Six months into implementation, the Ministry of Finance is rolling out a pilot programme and draft sanctions decree that together set some of the strictest entry barriers in Asia: VND 10 trillion (roughly USD 400 million) in charter capital for exchange operators, with 65% contributed by qualifying Vietnamese institutions.
The capital threshold
The VND 10 trillion requirement, established under Resolution 05/2025/NQ-CP, is not a typo. Exchange operators must maintain charter capital exceeding what most ASEAN commercial banks require for a banking license. Sixty-five percent of that capital must come from qualifying Vietnamese entities: banks, securities firms, insurers, tech companies, or fund managers. Foreign operators cannot go it alone.
The resolution also mandates Level 4 cybersecurity certification under Vietnam's national cybersecurity laws, the highest tier available. Crypto assets are recognized as property under the Civil Code (they can be owned, transferred, and inherited) but explicitly excluded from use as a payment method.
The sanctions playbook
The MOF's draft Administrative Sanctions Decree, released for public consultation in November 2025, sets the enforcement teeth. Maximum fines reach VND 200 million (~USD 7,700) for organizations and VND 100 million (~USD 3,800) for individuals per violation. Trading on unlicensed platforms: VND 10 to 30 million. KYC failures: VND 50 to 70 million. Offering crypto without a prospectus or authorization: VND 180 to 200 million plus a three-to-six-month business suspension.
These penalty amounts look modest until you realize they apply per violation. The draft also allows license revocation for up to six months and issuance suspension for up to 12 months.
Twenty-one million users, zero licensed exchanges
Vietnam ranks seventh globally in crypto adoption. Roughly 21.2 million adults have used digital assets, and annual transaction volumes exceed USD 100 billion, about 25% of the country's GDP. All of this has occurred in a market with zero licensed exchanges.
The five-year pilot programme running from 2025 to 2030 is supposed to bridge that gap. The MOF began accepting license applications in January 2026 under Decision No. 96/QD-BTC. Whether anyone can actually meet the VND 10 trillion threshold is the question nobody in the Ministry seems eager to answer. The requirement effectively limits exchange operation to joint ventures anchored by Vietnam's largest financial institutions, which may be exactly the point.
Taxation rules remain provisional, currently handled under securities rules. Dedicated accounting standards are expected by March 2026.
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