Vietnam’s digital asset market is no longer a grey zone. The Law on Digital Technology Industry (No. 71/2025/QH15), effective January 1, 2026, reclassified digital assets as property under the Civil Code and initiated a formal licensing regime for exchanges and custodians. For financial institutions, fintechs, and infrastructure providers, this signals that Vietnam is moving from one of Asia’s highest-volume informal markets into a regulated, onshore industry. The infrastructure decisions made now will determine who operates at scale when the pilot matures.
Vietnam’s Digital Asset Market: The Institutional Case
Vietnam ranks 4th globally in Chainalysis’ 2025 Global Crypto Adoption Index, behind only India, the United States, and Pakistan. An estimated 17 million Vietnamese, roughly one in six of the population, hold digital assets, with annual on-chain transaction volume estimated at over USD 100 billion (VinaCapital). APAC on-chain transaction value grew from USD 1.4 trillion to USD 2.36 trillion year-on-year through mid-2025, with Vietnam a principal contributor.
The use cases extend beyond speculation. Vietnam received approximately USD 16 billion in remittances in 2024 (World Bank), placing it among the ten largest recipient markets globally. These are large, recurring cross-border flows where stablecoin rails compete directly on cost and speed against legacy correspondent banking.
The builder ecosystem reinforces the institutional case. Sky Mavis (Axie Infinity), Kyber Network, TomoChain, Ronin, and Coin98 all originated from Vietnam’s engineering talent pool. At least ten Vietnamese blockchain startups have crossed USD 100 million in valuation. Da Nang and Ho Chi Minh City have been designated sites for international financial centres, with government incentives targeting crypto asset service providers and digital technology enterprises. This is a policy environment actively trying to onshore digital asset activity, not merely tolerate it.
The 2025 Regulatory Framework: What the Rules Actually Say
Two instruments govern Vietnam’s virtual asset market as of 2026.
The Law on Digital Technology Industry (No. 71/2025/QH15), passed June 14, 2025 and effective January 1, 2026, recognises digital assets as property for the first time under Vietnamese law. Digital assets can be owned, transferred, and inherited under the Civil Code. This creates the foundational legal basis for institutional custody: assets that are legally property can be legally held, segregated, and transferred on behalf of clients.
Resolution No. 05/2025/NQ-CP, issued September 9, 2025, establishes a five-year pilot programme (2025 to 2030) for the issuance, trading, and supervision of crypto assets. The resolution sets the following operational rules:
- Settlement currency: All offering, issuance, trading, and settlement must be conducted in Vietnamese dong. Foreign currency settlement is not permitted.
- Minimum charter capital: Licensed exchange operators must hold minimum charter capital of VND 10 trillion, approximately USD 380 to 410 million depending on prevailing exchange rates.
- Ownership structure: At least 65 percent of capital must originate from institutional investors, with a minimum of two financial institutions holding over 35 percent combined. Foreign ownership is capped at 49 percent.
- New crypto asset offerings and issuances during the pilot may only be made to foreign investors; defined as foreign-national individuals and entities incorporated under foreign law. Domestic investors, including foreign-invested enterprises incorporated under Vietnamese law, are not eligible for new issuances.
- Domestic investors who held crypto assets prior to September 9, 2025 (the Resolution’s effective date) may open accounts with Ministry of Finance-licensed service providers solely for the custody and sale of those pre-existing holdings.
- Licensing authority: Only Vietnamese-incorporated entities licensed by the Ministry of Finance may operate. Oversight is shared across the Ministry of Finance, the State Bank of Vietnam, and the Ministry of Public Security. Vietnam’s enforcement window opens September 1, 2026, when domestic trading activity must move onto licensed platforms, making the infrastructure decisions being made today directly determinative of who captures Vietnam’s 17 million crypto holders at scale.
- IT security: Operators must certify their infrastructure to Level 4 under Vietnam’s national information security standard.
- The licensing process is governed by Decision No. 96/QD-BTC, dated January 20, 2026. Applications have been accepted by the State Securities Commission from January 20, 2026. The Ministry of Finance targets Q3 2026 for the first licence to be issued.
- The custody definition under the pilot is explicit: custody means “the receipt, storage, safekeeping, and transfer of crypto assets on behalf of clients, and assisting clients in exercising rights relating to custodied crypto assets.” This is an active infrastructure obligation, not a passive holding function.
- Five Vietnamese entities have cleared initial screening under Resolution No. 05/2025/NQ-CP:
- VIXEX (VIX Digital Asset Exchange JSC) is backed by VIX Securities and FTG Vietnam JSC, with technology infrastructure being built in partnership with FPT. It is headquartered in Hanoi and represents the securities brokerage sector’s entry into the pilot.
- SCEX (Sacom Crypto Asset Exchange JSC, formerly LPEX) rebranded from Loc Phat Vietnam Crypto Asset Exchange after restructuring its shareholder base to incorporate LPBank and Sacombank. The rebrand signals a shift toward institutional backing and alignment with international compliance standards.
- CAEX (Vietnam Prosperity Crypto Asset Exchange JSC) operates within the VPBank ecosystem and has received strategic investment from OKX Ventures and HashKey Capital toward meeting the VND 10 trillion capital threshold. CAEX has publicly confirmed its technology stack includes cold wallets, HSM, KYB onboarding, and VND-denominated trading. Website: caex.com.vn
- TCEX (Techcom Digital Asset Exchange JSC) is anchored by Techcombank and its securities arm TCBS, which has already integrated crypto asset price tracking into its platform. TCEX and SCEX were the first two applicants to advance to the preliminary review round under Decision No. 96/QD-BTC.
- Vietnam Digital Assets JSC (Sun Group ecosystem) was incorporated on January 21, 2026, with Sun Group holding a 64 percent controlling stake alongside Innovation IT Services (35 percent) and PetroVietnam Securities (1 percent). It is headquartered at the Sun Ancora building in Hanoi. Two applicants, Dolphinex and SSI Digital Technology (SSID), submitted incomplete dossiers and did not clear initial screening.
What Licensed Operators Must Build: Infrastructure Requirements
The pilot’s implementing rules translate directly into infrastructure obligations that licensed exchanges and custodians must satisfy before going live. These are gating conditions for licence issuance, not post-licensing recommendations.
Client asset segregation
Custodied assets must be held separately from the operator’s own balance sheet. At the wallet infrastructure layer, each client’s assets must sit in segregated wallets, not a pooled operator wallet. Policy-enforced segregation, where the system itself prevents commingling rather than relying on manual controls, is the only operationally reliable approach at institutional scale.
Key management with no single point of failure
Documented key management procedures must eliminate single points of compromise. Multi-party computation (MPC) distributes key shares across multiple parties so that no single server, person, or location can sign a transaction unilaterally. Both MPC and HSM-based approaches satisfy the requirement. MPC offers operational flexibility for multi-chain environments and allows all key material to remain onshore, addressing the data localisation rule simultaneously.
Data localisation
Sensitive datasets must be stored on infrastructure physically located in Vietnam and available for regulatory inspection. Key material and transaction records must reside on onshore servers. This is a binding architectural constraint, not a preference.
Level-4 information system security certification
Licensed operators must certify their infrastructure to Vietnam’s national information security standard at Level 4, requiring documented security architecture, access controls, incident response procedures, and independent audit.
AML compliance
Transaction screening and reporting obligations run to the Ministry of Public Security and the State Bank of Vietnam. AML controls must be embedded in the transaction flow, not applied retrospectively.
Audit-ready reporting
The Ministry of Finance requires documented custody arrangements and transaction reporting. Infrastructure that generates exportable, regulator-ready records significantly reduces the compliance overhead of the licensing inspection.
For licensed operators, building these capabilities from scratch is both time-consuming and high-risk. Partnering with proven institutional custody infrastructure that has already been tested across equivalent regulatory regimes is the operationally sound approach.
How Liminal Supports Exchanges and Institutions in Vietnam
Liminal’s wallet infrastructure maps directly to the obligations Vietnam’s pilot programme imposes.
MPC wallet infrastructure
distributes key shares with no single point of failure, satisfying the pilot’s key management requirements. Liminal’s MPC architecture supports deployment on client-specified infrastructure, including onshore Vietnamese data centres, to satisfy the data localisation rule. All key material can remain within Vietnam’s borders while maintaining the resilience and operational flexibility institutional operators require. Multi-chain support covers the asset classes Vietnamese exchanges will be authorised to list under the pilot.
Policy-based transaction controls
Enforce client asset segregation at the infrastructure layer. Liminal’s policy engine applies multi-signatory approval workflows, counterparty allowlists, and transaction limits automatically, ensuring the operator’s governance rules and the regulator’s segregation requirements are enforced by the system, not by manual process.
Audit-ready reporting
Generates transaction-level records exportable for Ministry of Finance review and the infrastructure inspection required before a licence is granted under Decision No. 96/QD-BTC.
Certifications:
Liminal holds ISO 27001, ISO 27701, and SOC 2 Type 2 certifications. For exchanges moving through the Level-4 information security certification process, Liminal’s certified infrastructure reduces the compliance engineering burden significantly.
Liminal has secured over USD 100 billion in transaction volume across institutional clients in APAC and MENA. Institutions evaluating Vietnam’s pilot programme or building digital asset infrastructure for the APAC region can speak with Liminal’s institutional team to discuss custody architecture and compliance requirements.
Note: Liminal is not a registered crypto asset service provider in Vietnam and does not provide services directly to Vietnamese end-clients or domestic investors. Liminal’s infrastructure is available to licensed Vietnamese entities under technology partnership arrangements.
