Prospects of the Vietnamese digital asset market after Resolution 05/2025/NQ-CP

On September 9, 2025, the Government issued Resolution 05/2025/NQ-CP – a groundbreaking document that officially opens the pilot phase for the management and development of the digital asset market in Vietnam. This is the first time a clear legal framework has been established for a sector that has long operated in the "zone", creating significant opportunities for legitimate development while also bringing considerable challenges for enterprises, investors, and regulatory authorities.

###Key points of the Resolution

Resolution 05/2025/NQ-CP establishes the first legal framework for the digital asset market in Vietnam through a 5-year pilot program. During this period, key activities such as offering, issuing, organizing trading markets, and providing cryptocurrency services will be allowed to be implemented, but under strict supervision by the State. Notably, cryptocurrencies are recognized within the testing framework, but the issuance and offering must meet various conditions: transparent disclosure, limitation of participants, and full compliance with legal procedures. This is to ensure investor rights while minimizing the risk of abuse during the initial opening phase.

Another important highlight is that all transactions must be conducted through organizations licensed by the Ministry of Finance. Domestic investors must open accounts with these entities, and in the future, transactions outside the system may face administrative penalties, or even criminal charges. This approach reflects a clear direction: The state aims not only to establish a risk control mechanism from the outset but also to create a transparent, professional, and sustainable playing field, where financial institutions, technology companies, and investors can participate with legal assurance.

Resolution 05/2025/NQ-CP###Opportunities from the new legal framework

First, transparency and legal safety will be strengthened. Resolution 05/2025/NQ-CP lays the foundation for businesses and investors to operate without the concern of the previous "half-legal, half-informal" status. This is especially important to unlock funding from large investment funds and financial institutions.

Secondly, Vietnam has the opportunity to attract mainstream capital and FDI. When the legal framework is clear, international institutional investors can view Vietnam as a potential destination for deploying tokenized asset products. In the context where many countries in the region remain cautious, Vietnam's lead will be a significant competitive advantage.

On Tuesday, the resolution also paves the way for the development of domestic digital financial infrastructure. Licensed exchanges, custody services, digital asset management platforms, and solutions for tokenizing real estate and commodities could all see explosive growth in the coming years. This will not only boost the digital asset market but also enhance the competitiveness of the entire financial system in Vietnam.

Finally, centralized management also helps control the risks of money laundering, terrorism financing, and cybersecurity. Instead of allowing funds to flow freely, transactions are recorded and monitored through official channels, thereby increasing investor protection and stabilizing the system.

###Risks and unintended consequences

However, the new legal framework is not without its downsides. The openness of the market will be limited in the initial stage. Allowing transactions only through licensed organizations may cause some liquidity to flow into "grey" channels or abroad, reducing the competitiveness of domestic exchanges.

Secondly, businesses will face high compliance costs. Meeting requirements for capital, technology, custody, periodic reporting, or insurance will make it difficult for many small startups to participate, leading to the risk of a "market only for the big players."

Another risk is the possibility of relocating operations abroad. If the domestic issuance and trading conditions are too strict, many projects may choose to list their tokens in other markets, leading to a loss of resources.

Finally, the effectiveness of implementation largely depends on the capacity for monitoring and inter-agency coordination. The Ministry of Finance, the State Bank, the Ministry of Public Security, and other agencies must coordinate closely; otherwise, the goals of transparency and investor protection will be difficult to achieve.

###Securities companies actively enter the market

Resolution 05/2025/NQ-CP marks an important milestone, officially paving the way for the pilot program of issuing, trading, and providing cryptocurrency services under the close supervision of the State. The biggest highlight in this legal framework is the requirement for financial capacity: participating enterprises must have a minimum charter capital of 10 trillion VND.

Not only that, the shareholder structure is also strictly regulated to ensure transparency and financial strength: at least 65% of the capital must be owned by organizations, and at least 35% must come from two or more financial or technology organizations. These conditions are both a challenge and a motivation, forcing businesses to prepare thoroughly if they want to enter the new game.

This tight binding has created a momentum that has prompted many securities companies, banks, and major financial institutions to act swiftly. With strong capital potential, risk management experience, and a vast customer network, they are positioning themselves as "pioneers," determined not to miss opportunities in a digital asset market that is considered full of potential.

Among the fast-moving financial organizations participating, SSI Securities Corporation stands out as one of the pioneering entities. Since 2022, SSI has proactively established SSI Digital Corporation with a charter capital of 200 billion VND, laying the foundation for a comprehensive digital financial ecosystem. Not only stopping at preparing internal resources, SSI has also actively expanded international relations through strategic cooperation agreements with Tether, U2U Network, and Amazon Web Services, aiming to develop blockchain infrastructure as well as cloud computing services. This early preparation and long-term vision have helped SSI affirm its pioneering role, ready to seize opportunities as the cryptocurrency market officially enters the pilot phase.

Techcom Securities (TCBS) also demonstrates a remarkable agility in the new race. In May 2025, the company launched the Techcom Cryptocurrency Exchange (TCEX) with an initial charter capital of 3 billion VND, and shortly after, it raised the capital to 101 billion VND. Meanwhile, VIX Securities also joined the race by establishing VIXEX with an initial capital of 150 billion VND, before quickly expanding to 1 trillion VND. These strong and continuous moves demonstrate the determination of securities companies to assert their position and become important links in the digital asset ecosystem that is gradually forming.

###Banks strengthen digital infrastructure and international cooperation

Alongside the proactive stance of securities companies, commercial banks are also accelerating their entry, demonstrating the increasingly evident heat of the digital asset market. According to the regulations in Resolution 05/2025/NQ-CP, a digital asset exchange seeking licensing must have the participation of major shareholders in the financial or technology sectors. This has prompted banks not only to leverage their existing internal strengths but also to actively seek international strategic partners to enhance technological capabilities and ensure compliance with global standards.

One of the typical transactions is the collaboration between Military Commercial Joint Stock Bank (MB) and Dunamu Group – the entity behind Upbit, the world's leading cryptocurrency exchange with a trading volume in 2024 exceeding 1.1 trillion USD. According to the agreement, Dunamu will assist MB in technology transfer, establishing legal compliance mechanisms, and implementing investor protection measures. This is seen as a strategic move, helping MB gain an important competitive advantage during the pilot phase.

Meanwhile, Vietnam Prosperity Joint Stock Commercial Bank (VPBank) is also urgently completing its plan to participate in the market. Through VPBank Securities (VPBankS), this bank is pioneering the development of its own cryptocurrency exchange. Notably, VPBankS is also preparing for an IPO to raise capital both domestically and internationally, strengthening its financial capacity and laying the foundation for its ambition to participate extensively in the pilot program.

The decisive actions from both securities companies and banks not only demonstrate the strong involvement of traditional financial entities but also signal a dynamic and fiercely competitive landscape for Vietnam's digital asset market in the upcoming period.

###Short-term and Medium – Long-term Prospects

In the next 6–18 months, the Vietnamese digital asset market will enter a startup phase with the emergence of the first licensed exchanges and service providers. During this phase, pioneering organizations are likely to focus on serving institutional clients and foreign investors – those who are already familiar with risk management standards and strict legal frameworks. In contrast, domestic individual investors will need more time to adapt, as account opening procedures, identity verification (KYC), and initial limits may make them more cautious. At the same time, the market will witness a strong wave of cleansing: platforms that do not meet legal requirements will have to cease operations, merge, or shift to foreign markets. This will be a necessary step to shape a transparent and sustainable playing field.

In the medium and long term (2–5 years), if the pilot program is implemented smoothly, Vietnam has the opportunity to rise to become a managed digital asset hub in Southeast Asia. With a young population, high rates of Internet and mobile device usage, along with a rapidly expanding financial-technology ecosystem, the market size could potentially reach from tens to hundreds of billions of USD, depending on the development scenario. However, to realize this vision, the government needs to be steadfast with the "step-by-step opening" strategy, while also clarifying the licensing criteria, maintaining policy stability, and enhancing supervision. Only by combining flexibility in management with market discipline can Vietnam build an attractive and safe environment for both domestic and foreign investors, thereby affirming its position on the regional digital asset map.

###Recommendations for stakeholders

To ensure that the Vietnamese digital asset market operates effectively and develops sustainably after Resolution 05/2025/NQ-CP, each participating group needs to have its own adaptation strategy. For individual investors, the most important thing is to closely monitor the list of licensed organizations and only participate in products that fall within the legal framework. This not only helps minimize legal risks but also protects capital safety against unusual fluctuations in the "gray" market.

For startups and exchanges, compliance requirements will become increasingly strict, thus it is necessary to proactively establish KYC/AML systems, custody solutions, and transparent reporting mechanisms. Collaboration with traditional financial institutions will be a wise choice, helping to share compliance costs and build trust with both investors and regulatory authorities.

For managers and policymakers, the "step-by-step opening" strategy is a reasonable approach: simultaneously implementing licensing, monitoring, and adjusting based on real market data. At the same time, it is necessary to invest heavily in blockchain analysis tools, train a specialized workforce, and clarify the licensing criteria. Only by synchronizing these elements can the market operate transparently, safely, and build long-term trust.

In general, Resolution 05/2025/NQ-CP marks a historic turning point: bringing Vietnam's digital asset market from a vague "zone" into a regulated pilot phase. The prospects are clear – a transparent playground that attracts mainstream capital and promotes innovation in digital financial infrastructure. However, the final results will depend heavily on the implementation: if the licensing mechanism is transparent, supervision is effective, and policies are flexible, Vietnam could rise to become the digital asset hub of the region. Conversely, if regulations are too rigid or supervision is inconsistent, the market risks stagnation and losing its golden opportunity in the digital asset era.

Emma