Ministry of Finance Vietnam is currently seeking feedback on the draft Circular "Guidelines for Accounting for Organizations Participating in the Cryptocurrency Market during the Pilot Phase," marking an important step in perfecting the legal framework for the digital asset market in Vietnam.
1. How are crypto assets classified according to accounting standards?
According to the draft, the Ministry of Finance approaches crypto assets from two perspectives: referencing international accounting standards and considering their legal nature. Resolution 05 established.
👉 According to international accounting standards, crypto assets can be XEM from three perspectives.
Firstly, in cases where a business holds crypto assets for the purpose of regular buying and selling to generate profit, such as proprietary trading exchanges, market makers, or crypto trading firms, the crypto assets may be classified as inventory under IAS 2.
IFRS has a precedent allowing "commodity broker-traders" to recognize inventory at fair value through profit/loss (FVTPL), and the draft allows a similar approach to crypto proprietary trading.
Secondly, in essence, there are some Token that do possess the characteristics of financial instruments, but according to Resolution 05, crypto assets It is neither a security nor a financial asset. Therefore, the Ministry of Finance excludes the classification of tokenized assets under IFRS 9.
Tuesday, In most cases, crypto assets are not money, have no physical form, but can be controlled through a private key, and have market value, so they can be XEM "intangible assets".
👉 In terms of legal nature, according to Resolution 05 defines crypto assets as digital assets whose underlying assets are real assets, not money, not securities, and not financial assets.
Custody and trading are only conducted on licensed platforms, and value is determined through market transactions. With a clear investment orientation, this asset class is categorized as a particular type. "Non-financial investment assets".
Based on that, the Ministry of Finance stated that during the pilot phase, the accounting circular will Vai as an "initial guiding framework," based on Resolution 05, Vietnamese Accounting Standards, and the accounting regime for enterprises. These regulations will continue to be reviewed, adjusted, and supplemented as the market operates and new practical situations arise.
2. Who is this application for?
The draft Circular applies to organizations participating in the cryptocurrency market in Vietnam during the pilot period, including:
(i) Organizations providing crypto asset services (exchanges, custody services, issuance platforms);
(ii) The issuer of the crypto asset;
(iii) The investor is an organization established and operating under Vietnamese law.
For organizations providing crypto asset services, the draft regulations stipulate that revenue from activities such as organizing trading markets, custody, and providing issuance platforms is subject to these regulations. Recorded as revenue from sales and services rendered. According to the corporate accounting system.
Regarding custody operations, the draft emphasizes the principle Complete separation between customer assets and the company's own assets. provide services.
Organizations must Maintain detailed ledgers for each customer and each type of crypto asset . Revenue is recorded from custody fees, asset management fees, crypto asset transfer fees, collateral asset management fees, and other related transactions. Simultaneously, the business must track accounts receivable from customers in detail through the "Accounts Receivable from Customers" account.
With activity Proprietary trading of crypto assets is considered by the draft to be an operation similar in nature to securities trading.
Revenue and expenses are recorded as trading securities, and the enterprise must set aside risk provisions similar to the mechanism applied to securities companies.
3. Token Issuance is accounted for as a Capital activity.
Regarding issuers of crypto assets, Resolution 05 defines them as Vietnamese enterprises operating under the Enterprise Law. Although there are no detailed regulations on secondary transactions, according to the State Securities Commission, the proceeds from these transactions are considered acceptable. The Token Issuance activity is suitable for recognition as a liability.
Accordingly, the draft Circular stipulates that the offering and issuance of crypto assets will be accounted for similarly to corporate Capital activities, based on the economic nature of the transaction rather than the legal form of the Token.
4. Institutional investors: Accounted for as financial investments.
For investors, due to the limitations of current accounting laws, the draft only provides accounting guidance for domestic institutional investors.
Accordingly, the buying and selling of crypto assets on licensed platforms is accounted for similarly to financial investment activities, and the appropriate recording method is chosen based on the purpose of holding (short-term, long-term, business, or investment).
