Resolution 5/2025 establishes the first legal framework for Vietnam’s digital asset market. The pilot phase will last five years. 

The resolution outlines the pilot implementation of offering and issuing digital assets, organizing digital asset trading markets, providing digital asset services, and the state's management of the digital asset market in Vietnam.

The pilot will be implemented cautiously and under control, with a roadmap aligned with actual conditions. It emphasizes safety, transparency, efficiency, and protection of legal rights and interests for organizations and individuals participating in the digital asset market.

Key points of the resolution include: only Vietnamese enterprises can operate trading platforms; the minimum charter capital required to be licensed is VND10,000 billion; and at least 65 percent of the charter capital must be contributed by institutions, with more than 35 percent held by at least two institutions such as banks, securities firms, fund managers, insurance companies, or tech enterprises.

Digital assets can only be offered or issued to foreign investors. Initial transactions will be limited between foreign investors and through licensed organizations. Domestic investors are allowed to open accounts at organizations licensed by the Ministry of Finance.

The objective is caution and control, with a focus on protecting domestic investors. The state is conditionally opening the digital asset market, not liberalizing it.

According to the latest report, Vietnam ranks among the top five globally in crypto adoption, with over 21 million people owning digital assets. The estimated value of cryptocurrencies held by Vietnamese individuals has reached hundreds of billions of dollars.

Forecasted impact

With the VND10,000 billion (about $377 million) charter capital requirement, large financial institutions such as banks, securities firms, fund managers, and insurers, or alliances between these, have the opportunity to establish exchanges.

Some securities companies have already made preparations, such as SSI, TCBS, and VIX. Others with support from parent banks, such as MBS, HDBS, and VPBankS, also show potential to form qualified entities to offer digital asset trading services.

However, mainstream trading activities may begin late due to licensing procedures, transparency/reporting standards, custody systems, anti-money laundering (AML) compliance, and know-your-customer (KYC) verification. The early stage will focus on infrastructure, testing, and small-scale pilots.

The restriction on issuing digital assets to domestic investors may hinder initial coin offerings (ICO) or mass token sales. Individual investors may still hold “off-market” digital assets, but will face legal risks if trading through unlicensed platforms (subject to enforcement six months after the first license is issued).

At this stage, Resolution 5 only sets the first legal framework for Vietnam's digital asset market, with a five-year pilot timeline. As a result, multiple future scenarios are possible.

Trung Hung, a crypto investor in Hanoi, believes that in a baseline scenario, the market would develop slowly but steadily. Only a few exchanges would be licensed, mostly run large enterprises or joint ventures. The focus would be on tokenizing traditional assets, token certificates, and institutional services.

Initial liquidity would be low but is expected to grow as institutional and foreign investors enter. During this process, regulations would continuously be adjusted based on pilot data.

In a favorable scenario, banks and securities firms would capitalize on the opportunity by partnering with tech companies to implement efficient custody and KYC/AML systems. This would help attract significant foreign capital. Some real estate and bond tokenization products could be launched domestically. The market would grow faster than expected but remain within regulatory boundaries.

In an unfavorable scenario, high capital requirements and issuance restrictions for domestic investors could slow formal activities. Meanwhile, the unofficial (OTC) market could remain active, posing systemic risks and legal pressure. Domestic investors might continue to trade via illegal foreign platforms or underground channels.

Some stocks are expected to benefit from Resolution 5. The securities group, including SSI, TCBS, and VIX, has already prepared for entry into the digital asset market. Banks such as TCB, MBB, and VPB have advantages in capital and financial ecosystems.

Manh Ha