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Key Takeaways
No Applicants Yet: Vietnam’s new crypto trading pilot has received zero applications since launch, largely due to its strict entry requirements.
High Capital Thresholds: Firms must meet a minimum capital requirement of 10 trillion VND (about $379 million), limiting participation to large financial entities.
Regulatory Constraints: The pilot excludes stablecoins and tokenised securities, narrowing business opportunities and discouraging industry interest.
Vietnam’s much-anticipated five-year crypto trading pilot has thus far drawn zero applicants, despite strong global and local interest in regulated digital asset markets.
Overview
At a recent briefing, Deputy Finance Minister Nguyen Duc Chi confirmed that no proposals have been submitted, citing steep entry requirements and a narrow permissible product range as key deterrents. Chi highlighted that the program would accommodate up to five participants and added that the ministry is fast-tracking procedures to ensure the first qualified company can obtain a licence and start operating as soon as possible.
Chi said,
“As of now, the ministry has not received any proposals from enterprises.”
Chi added,
“We hope to launch this pilot before 2026, however the progress will depend on how well enterprises can meet the required conditions.”
The Pilot’s Ambitious Design – and Why It Scares Off Applicants
Vietnam launched a regulatory framework for crypto with Resolution 05/2025, beginning September 9, 2025, aiming to pilot a domestic digital asset trading regime through 2030. Under the plan, up to five qualified firms will be licensed to run services under strict oversight.
However, the design includes several conditions that arguably elevate it closer to banking regulation than fintech sandbox:
- A minimum charter capital of 10 trillion dong (≈ USD 379 million) is mandated for any crypto asset service provider (CASP).
- Only Vietnamese entities may issue or operate digital assets, and all transactions must be denominated in Vietnamese đồng, limiting flexibility.
- Importantly, the framework disallows stablecoins and securities-backed tokens, excluding products like USDT, USDC, or tokenised treasuries.
These constraints significantly shrink the viable business models and raise compliance burdens. Put simply, many firms may find the risk, capital burden, and narrow profit margin unattractive given what alternative markets offer.
Enforcement Lags, Caution, and Market Realities
Despite the pilot’s official launch, enforcement details—and even licensing mechanics—remain under development. Deputy Minister Chi noted that progress depends on firms’ ability to meet conditions, and the government is working to expedite licensing toward a goal of launching the first participants before 2026.
But in the meantime, firms remain cautious. Several are reportedly preparing to expand or adjust their business lines ahead of applying, but none have committed yet. The opacity around tax treatment, accounting standards, oversight coordination (e.g. with the State Bank of Vietnam and security regulators), and overall enforcement remains a barrier too.
Meanwhile, despite the pilot’s slow rollout, crypto activity among Vietnamese users continues apace—largely through offshore platforms. Vietnam ranks fourth globally in Chainalysis’ 2025 crypto adoption index, and annual trading volumes have exceeded USD 100 billion.
This divergence underscores the tension: user demand is high, but the regulated offering is not keeping pace.
Risks and Recommendations: Can Vietnam Salvage Its Pilot?
Vietnam’s approach illustrates a core trade-off in crypto regulation: too soft, and risks proliferate; too rigid, and innovation stalls. In its current form, the pilot leans heavily toward the latter.
Risks:
- The absence of participants means the pilot may fail to generate meaningful data or outcomes before its 2026 launch goal.
- Vietnam could fall behind regional peers (Singapore, Hong Kong, Japan), which permit lower capital thresholds and broader product scopes.
- The inability to import stablecoins or tokenised financial instruments may limit appeal to institutional investors and ecosystem builders.
Potential adjustments:
- Reducing capital requirements or introducing graded tiers might attract more participants.
- Allowing tokenised securities or a controlled subset of stablecoins could expand business models.
- Greater clarity and speed in licensing, taxation, and oversight rules may reduce first-mover risk.
If Vietnam wants the pilot to succeed, it must strike a better balance between regulation and market practicality. As of now, it remains an ambitious framework without any takers.