Key Takeaways
(We will keep the Key Takeaways at the beginning of the live article to give readers a quick overview and improve the reading experience.)
- Vietnam’s Law on Digital Technology Industry and Resolution No. 05/2025/NQ-CP establish the country’s first formal licensing framework for crypto-asset businesses.
- The types of digital asset businesses you can set up
- The regulatory framework and licensing procedures that apply
- What it takes to register, capitalise, and licence your business
- The infrastructure and compliance stack you need to launch
- A step-by-step path from entity setup to going live
Vietnam is becoming an increasingly important market for digital assets. Businesses planning to enter the market in 2026 need to understand the activity they intend to offer, whether it requires a licence, and what they need to have in place before launch.
Vietnam ranked fourth globally in Chainalysis’ 2025 Global Crypto Adoption Index, behind India, the United States and Pakistan. The country was also the third-largest crypto market in APAC by on-chain value received, behind India and Pakistan. Its on-chain value increased 55% year over year in the 12 months ending June 2025, highlighting the scale and continued growth of crypto activity in the market.
At the same time, Vietnam is moving towards a more formal regulatory framework for digital assets. The Law on Digital Technology Industry, which took effect on 1 January 2026, provides legal recognition and definitions for digital assets. Resolution No. 05/2025/NQ-CP, effective from 9 September 2025, established a five-year pilot covering crypto-asset issuance, trading, the organisation of crypto-asset trading markets and related services. Decision No. 96/QD-BTC, issued on 20 January 2026, sets out the administrative procedures for granting, adjusting and revoking licences to organise a crypto-asset trading market.
For businesses considering market entry, the key question is not simply whether Vietnam permits digital-asset activity. It is which business model they intend to operate, which rules apply and what they need to put in place before launch.
This article examines the main digital-asset business models available in Vietnam, the regulatory framework and licensing requirements that may apply, the capital and corporate requirements for regulated activities, the infrastructure and compliance controls needed to operate, and the steps involved in setting up and launching a digital-asset business in Vietnam in 2026.
Why Vietnam is a strategic market for digital asset businesses in 2026
Vietnam consistently ranks among the top countries in the world for grassroots cryptocurrency adoption, driven by remittances, retail involvement, and increased stablecoin usage. This demand existed before the introduction of a regulatory framework, so the shift toward regulation is significant.
An already significant user base is now complemented by a framework that allows entities to operate in the market under established rules.
Three changes would set 2026 as a pivotal year:
A transition to a formal regulatory framework: Businesses can now classify their activities under specific regulations and apply for the relevant licences, replacing an environment where the regulatory treatment of crypto-asset activities was less clearly defined.
Increase in institution and stablecoin use: Stablecoin use for payments and treasury management is increasing across Southeast Asia, creating greater demand for compliant custody, wallet infrastructure, and transaction monitoring in markets such as Vietnam.
Clear government objectives: The framework focuses on investor protection, AML/CFT, taxation, and market oversight. For operators, this provides greater clarity around the standards they need to meet and the controls they need to have in place.
The result is a market where businesses that establish the right regulatory structure and operational capabilities early can build credibility as Vietnam’s digital asset market develops.
What counts as a digital asset business in Vietnam
Each cryptocurrency-related business is regulated differently, and not every business needs a trading market license. Businesses must understand their activities and the corresponding regulation to adopt an appropriate licensing policy. Common activities include crypto asset trading and exchange operations, custody services, wallets and infrastructure, stablecoin and digital asset payments, and brokerage and OTC services.
The key distinction is between activities that require a licence and infrastructure or support roles that may not, though the latter can still fall into scope depending on exactly what they do.
How Vietnam’s Pilot Framework Classifies Each Digital Asset Business Model
The table below maps each major digital asset business model to its current regulatory position under Vietnam’s pilot framework.
| Business model | Regulatory position |
| Crypto-asset trading-market operator | Directly addressed by the Decision No. 96 licensing procedures, with substantive eligibility requirements under Resolution No. 05 |
| Custody service | Included in the broader crypto-asset service framework, but should not automatically be treated as a standalone licence category |
| Wallet or infrastructure provider | May operate as a technology or outsourcing provider depending on its functions; licensing depends on whether it performs regulated activities |
| Brokerage or OTC desk | Requires activity-specific analysis and should not automatically be treated as covered by the trading-market licence |
| Stablecoin or payment business | Requires separate analysis under crypto-asset and payment regulations |
| Issuance platform or issuer | Covered by the pilot in relevant circumstances, with requirements separate from those for trading-market operators |
Read More – Understanding the Travel Rule in Digital Asset Transactions
Vietnam’s Three-Layer Regulatory Framework for Digital Asset Businesses
Vietnam’s digital asset framework can be understood through three connected layers.
The statutory layer: The Law on Digital Technology Industry provides the legal framework for digital assets and took effect on 1 January 2026, establishing legal definitions and classifications for digital assets, including virtual assets and crypto assets.
The pilot layer: Resolution No. 05/2025/NQ-CP, effective from 9 September 2025, sets out the five-year pilot for the crypto-asset market, covering issuance, trading, custody, and related services.
The procedural layer: Decision No. 96/QĐ-BTC, issued on 20 January 2026, establishes the administrative procedures for granting, adjusting, and revoking the trading-market licence. The SSC receives applications; the Ministry of Finance issues the licence.
This distinction matters because Decision No. 96 provides the licensing pathway, while Resolution No. 05 contains the substantive eligibility and operating requirements.
Both documents are important to the licensing process. Decision No. 96 explains how to apply for the licence, while Resolution No. 05/2025/NQ-CP sets out the eligibility and operating requirements the applicant must meet.
What it takes to register and licence your business
Setting up a digital-asset business in Vietnam involves more than incorporating a company. Businesses offering regulated crypto-asset services must also meet the licensing requirements that apply to their specific activity.
Establish a local legal presence
A business seeking to operate a crypto-asset trading market under Vietnam’s pilot framework must be established as a Vietnamese company. This local entity applies for the licence, holds the required capital and is responsible for meeting regulatory and operational obligations.
Confirm the ownership structure early
The rules require applicants to use an eligible Vietnamese corporate form and limit foreign ownership. The ownership structure must also meet institutional-investor requirements. At least 65% of that capital must come from institutional shareholders, and total foreign ownership cannot exceed 49%. These rules can affect whether an international business enters Vietnam through a subsidiary, joint venture or local partnership, so the structure should be decided before the application process begins.
Plan for capital requirements
Licensed crypto-asset trading-market operators must maintain at least VND 10 trillion in contributed charter capital. This is a continuing licensing requirement, not an application fee or a one-time requirement. Businesses should therefore account for this capital requirement in their business model, funding plan, and long-term operating budget from the outset.
Because implementation details and requirements may change during the pilot phase, verify the current requirements against the State Securities Commission’s (SSC) published procedures before filing.
The infrastructure and compliance stack you need
Meeting the legal requirements secures the licence. Operating a business that holds and moves client assets safely requires an institutional-grade infrastructure and compliance stack. Regulators, counterparties, and clients will all assess how well the business manages custody, security, transactions, and compliance.
The core components are:
Institutional custody and key management
Digital-asset businesses need secure systems to manage private keys and approve transactions. MPC-based key management and hardware security modules can reduce reliance on a single key or individual, helping to protect assets from unauthorised access and key compromise.
Client-asset segregation
Businesses that hold customer assets need clear processes to keep those assets separate from company funds. This helps protect customers, supports accurate record-keeping and makes it easier to demonstrate how client assets are held and managed.
Security standards and certifications
Security certifications such as ISO 27001, ISO 27701 and SOC 2 Type II can help businesses demonstrate that their security, privacy and control frameworks have been independently assessed. The required or appropriate certifications will depend on the business model, regulatory expectations, and customer requirements.
AML, KYC and Travel Rule monitoring
Businesses operating under Vietnam’s pilot framework must maintain customer verification, sanctions screening, transaction monitoring, and Travel Rule data exchange. These controls support AML/CFT compliance and help businesses identify and report suspicious or high-risk activity.
Policy-based transaction controls
Transaction policies can define who can approve transfers, what approval steps are required, and when additional checks apply. These controls create a clear audit trail and help businesses apply their internal security and compliance procedures consistently.
Multi-chain wallet operations and operational resilience
Multi-chain wallet operations require reliable support for the digital assets and blockchain networks your clients use. At scale, this includes reconciliation, failover processes, and operational resilience measures that help maintain service continuity when underlying networks experience congestion or downtime. These capabilities are an important part of running a secure and reliable digital-asset business.
Each of these can be built in-house, but each also represents a specialist domain with a high security and compliance bar, which is why many operators source proven infrastructure rather than assemble it from scratch.
How to set up a digital asset business in Vietnam: step by step
Step 1: Choose the business model and confirm the regulatory scope
Decide what the business will offer and check whether the activity requires a licence under Vietnam’s pilot framework.
Step 2: Set up a Vietnamese entity and structure ownership
Establish the local entity and confirm the corporate form, shareholder structure and foreign-ownership arrangements.
Step 3: Meet the capital requirement
Secure the required contributed charter capital and account for ongoing financial obligations.
Step 4: Build or source the required infrastructure
Put custody, wallet, security and compliance systems in place, and decide whether to build them internally or use external providers.
Step 5: Prepare and submit your licence application to the SSC. Assemble the documentation required under Decision. 96 and file it through the SSC’s prescribed procedure.
Step 6: Launch operations and meet ongoing obligations. Once licensed, go live and put in place continuous reporting, audit, capital maintenance, and transaction monitoring as required by the pilot framework.
The order matters. Confirming scope and structure before building infrastructure or filing prevents costly rework, and having compliant infrastructure in place strengthens a licence application rather than following it.
Step 7: Prepare and submit your licence application to the SSC
For regulated activities, assemble the documentation required under Decision No. 96 and file it through the SSC’s prescribed procedures.
Step 8: Launch operations and maintain ongoing obligations
Once licensed, go live and put in place continuous reporting, audit, capital maintenance, and transaction monitoring as required by the pilot framework.
Key considerations before you start
Before entity formation or a licence application, work through four questions. They determine whether your plan is viable and correctly scoped.
Assess whether your activity actually needs a licence: Not every digital asset business requires a market-operator licence. Mapping your activity to the regulated categories first prevents you from pursuing a licensing timeline you may not need or, worse, discovering mid-build that you do.
Build a realistic business case and budget: Account for the full cost of launching and running the business, not just incorporation or application fees. This includes capital requirements, infrastructure, compliance tools, staffing, legal support, security and day-to-day operating costs. Ongoing compliance and security costs can be substantial, so include them in financial planning from the beginning.
Decide whether to build or buy infrastructure: Building custody, wallet and compliance systems in-house requires investment in engineering, security, compliance and integration capabilities. The security requirements are particularly high when a business holds or manages client assets. Using established infrastructure providers can reduce implementation work and help businesses launch faster, especially where a licensing process or market-entry timeline applies.
Plan for ongoing obligations: A licence is only the beginning. Licensed operators must maintain capital, meet reporting and audit requirements, monitor transactions, protect client assets, and maintain security controls throughout their operations. The business model should account for these long-term responsibilities, not only the requirements needed to obtain approval.
How Liminal supports digital asset businesses in Vietnam
For businesses entering Vietnam, building custody, wallet, and compliance infrastructure is one of the most time-consuming parts of the plan. It is also one of the most practical areas to source from an established provider rather than build from scratch.
Liminal offers institutional wallet and custody infrastructure designed for regulated exchanges, fintechs, banks, and digital asset businesses entering markets like Vietnam.
Liminal is built around MPC-based key management and policy-driven governance, and holds ISO 27001, ISO 27701, and SOC 2 Type II certifications. These provide independent assurance of security, privacy, and operational controls, supporting both licensing requirements and client trust.
The goal is to help new operators meet licensing and operational requirements and scale securely, without building core infrastructure from scratch. That includes:
- Institutional MPC wallet and key-management architecture
- Policy-driven transaction governance through Firewall
- Client-asset segregation and multi-chain wallet operations
- AML, Travel Rule, and screening integrations (TRM Labs, Notabene)
- APIs and enterprise integrations for exchange and treasury systems
- Custody and key management: Institutional MPC wallet architecture with client-asset segregation, supporting the pilot framework’s custody and key-management requirements.
- Transaction governance: Policy-driven transaction controls through Firewall, supporting internal approval processes, AML obligations, and audit-trail requirements.
- Travel Rule and AML compliance: Integrated screening and Travel Rule capabilities through TRM Labs and Notabene, supporting the pilot’s AML/CFT and Travel Rule requirements.
- Multi-chain wallet operations: Multi-chain wallet infrastructure that supports the digital assets and blockchain networks used by regulated exchanges and their clients.
- Regulatory certifications: ISO 27001, ISO 27701, and SOC 2 Type II certifications, providing assurance around the security, privacy, and operational controls relevant to the pilot framework.
For operators working within an active licensing window, sourcing proven infrastructure reduces implementation time and supports a stronger application dossier.
What setting up a digital asset business in Vietnam actually requires
Vietnam’s 2026 framework gives digital asset businesses a clearer route into a market with significant existing crypto adoption, but entry still requires careful planning.
The first step is to determine what the business actually does and which regulatory requirements apply. A trading-market operator, custody business, technology provider, issuer, and payment company should not assume they face the same licensing requirements.
For businesses seeking the trading-market licence, the requirements are substantial. They include Vietnamese corporate status, VND 10 trillion in contributed charter capital, institutional ownership requirements, foreign-ownership restrictions, qualified personnel, information-security standards, operational procedures, custody controls, and compliance systems.
The technology stack is equally important. Secure key management, client-asset segregation, transaction governance, monitoring, reconciliation, compliance integrations, and operational resilience need to be considered before launch.
