Barriers to entry
On the afternoon of January 20, 2026, the Vietnamese Ministry of Finance officially announced new administrative procedures in the field of crypto assets, to be implemented. Resolution No. 05/2025/NQ-CP Government's plan to pilot a cryptocurrency market.
According to Decision No. 96/QD- BTC, from today the management agency Begin accepting applications for license issuance, modification, and revocation. For organizations providing services to organize cryptocurrency trading markets, this "flips the switch" on the legal framework for a sector that has long operated in a gray area.
The official opening of application submissions means that domestic businesses can begin participating in the pilot program, bringing cryptocurrency trading activities under the direct supervision of financial regulators. Resolution 05 demonstrates Vietnam's cautious approach in setting criteria that bear the strong imprint of the traditional financial market.
Accordingly, the core conditions for obtaining a pilot license for the cryptocurrency market are as follows:
Legal status: Vietnamese enterprises, established and operating in Vietnam under the Enterprise Law, in the form of limited liability companies or joint-stock companies, that are registered to conduct business in services related to crypto assets.
Financial capacity: The minimum contributed charter Capital is 10,000 billion VND, entirely in Vietnamese Dong (VND).
Shareholder structure: At least 65% of the charter Capital must be held by institutional shareholders or members; of which over 35% must come from at least two institutions belonging to the group of commercial banks, securities companies, fund management companies, insurance companies, or technology enterprises. Capital institutions must have legal personality, be profitable for the two preceding years, with audited financial statements and full approval. Each institution or individual may only contribute Capital to one licensed entity; the total ownership ratio of foreign investors shall not exceed 49% of the charter Capital .
Headquarters and infrastructure: It has a legally registered office with adequate facilities, technical infrastructure, equipment, and technological systems suitable for providing crypto asset services.
Personnel requirements: The General Director (Director) must have a minimum of two years of experience in finance, securities, banking, insurance, or fund management. The Chief Technology Officer or equivalent position must have at least five years of experience in information technology. The company must have at least 10 technology personnel with legally required cybersecurity certifications and at least 10 professional personnel with securities trading licenses.
The market highlights the major players.
Immediately after the Ministry of Finance opened applications, investors began listing a number of companies considered qualified to participate in the pilot program, including several large commercial banks and securities companies such as SSI, TCBS, and VIX. However, to date, no company has officially confirmed that it has submitted an application for a license.
Notably, the opening of licensing is taking place in parallel with the completion of the regulatory framework. The Ministry of Finance is developing separate accounting guidelines for crypto assets to clarify how they are recognized, accounted for, and presented in financial statements. Simultaneously, the framework for administrative penalties in the field of crypto assets is also being finalized.
Given that Vietnamese investors continue to trade actively on international exchanges due to a lack of domestic platforms, the pilot program is expected to gradually bring this activity back into the formal legal framework. However, with high barriers to entry and strict oversight mechanisms, the cryptocurrency market in Vietnam is likely to develop according to a model with few players but high control, at least during the pilot phase.
The move to open up licensing comes amidst a simultaneous tightening of regulations on crypto transactions in Vietnam. Recently, authorities have The proposal suggests expanding the measures for handling violations , not just limiting them to fines, but also including confiscation of crypto assets and infringing means, and XEM criminal prosecution for serious offenses in digital asset transactions.
According to Coin68
