Vietnam’s First Crypto Exchange License Remains Unissued

Vietnam’s First Crypto Exchange License Remains Unissued

Vietnam’s Ministry of Finance received seven applications for crypto asset exchange licenses as of March 2026. Following an initial review, five were evaluated as “complete and valid,” but the country’s first Virtual Asset Service Provider (VASP) license has yet to be issued. This licensing round represents both a watershed moment for Vietnam’s shift from de facto tolerance to legal recognition of crypto assets, and an extreme benchmark for Asia-Pacific VASP regulatory frameworks with its globally unprecedented capital and equity thresholds.

Five Entities Pass Initial Evaluation; Two Rejected

Pursuant to Decision No. 96/QD-BTC (effective January 20, 2026), the Ministry of Finance leads the application process alongside the Ministry of Public Security and the State Bank of Vietnam, with the State Securities Commission (SSC) serving as the procedural hub. Among the seven initial applicants, five passed preliminary review: VIXEX (affiliated with VIX Securities), LPEX/SCEX (Lộc Phát, following a shareholder restructuring that brought in LPBank and Sacombank), CAEX (VPBank ecosystem, with strategic equity investments from OKX Ventures and HashKey Capital), TCEX (affiliated with Techcombank), and Vietnam Digital Assets JSC (64% owned by Sun Group). The other two applicants, Dolphinex and SSI Digital Technology (SSID), were deemed invalid due to incomplete charters and personnel documentation.

An Intriguing Detail: South Korean Exchange Partners Left Out

South Korean exchanges Dunamu (Upbit’s parent company) and Bithumb had previously signed technical cooperation MOUs with MB Bank and an SSI subsidiary, respectively, to enter the Vietnamese market. Neither local partner made the initial shortlisted five. In contrast, OKX Ventures and HashKey Capital chose to acquire direct equity in the already approved CAEX—securing equity in a licensed entity within the 49% foreign ownership cap while providing technology, security, and liquidity integration. The diverging fates of these two paths confirm a clear entry logic under Vietnam’s regime: equity binding with a licensed entity far outperforms technical partnerships waiting for a local partner to pass review.

World’s Toughest Entry Barriers: VND 10 Trillion Capital + 65% Institutional Ownership + 49% Foreign Limit Vietnam’s licensing thresholds are in a league of their own globally:

• Paid-in Capital: Minimum VND 10 trillion (~USD 380 million).

• Institutional Ownership: At least 65% held by institutional shareholders (banks, brokerages, funds, insurers, or tech firms), with at least 35% combinedly held by two or more institutional entities.

• Foreign Ownership Limit: Capped at 49%.

Comparison: Hong Kong’s VATP requires a minimum capital of just HKD 5 million, Singapore’s MPI base capital is SGD 250,000, and the highest MiCA category in the EU requires €150,000. Vietnam’s requirements are several orders of magnitude higher—less a standard licensing fee than an explicit policy statement: only financial conglomerates and state-backed players need apply.

Regulating Exchanges as “Financial Market Infrastructure”

Rather than treating crypto exchanges as payment tools, Vietnam regulates them as financial market infrastructure. Licensees must comply with Level 4 Information System Security Certification, MPC/HSM distributed key management (eliminating single-point signature risks), complete separation of customer and proprietary assets (individual wallets per customer), localized sensitive data storage, and mandatory AML reporting to the Ministry of Public Security and the State Bank of Vietnam. This directly addresses Vietnam’s placement on the FATF grey list since June 2023, where the unregulated crypto sector was identified as a primary risk area. Licensing is fundamentally an institutional response to FATF anti-money laundering compliance pressure.

Exclusive Fiat Pricing and a “License First, Block Later” Enforcement Strategy

Trading will be settled exclusively in Vietnamese Dong (VND). Crucially, the enforcement mechanism sets a clear timeline: within six months of the first license being issued, domestic investors must migrate their trading to licensed platforms. Offshoring to unlicensed platforms will carry administrative penalties and potential criminal prosecution, supported by Ministry of Finance rules banning citizens from trading on foreign exchanges. This sequence fixes the compliance window for cross-border platforms precisely to the issuance of the first license.

Taxation Aligned with Securities: 0.1% Transfer Tax + 20% CIT

Under Circulars 32/2026/TT-BTC and 41/2026/TT-BTC, crypto asset transactions are treated like securities:

• Personal Income Tax: Licensed platforms must withhold a 0.1% tax on each transfer amount (matching the stamp duty rate for stock trades).

• Corporate Income Tax: Enterprises pay a standard 20% CIT on net taxable income.

• Value-Added Tax: Exempt at the trading stage.

Shifting the withholding obligation to platforms rather than individual taxpayers embeds tax collection costs directly within licensed institutions.

Summary （Vietnam crypto exchange）

By imposing the world’s highest capital and equity barriers, Vietnam has turned crypto exchange licensing into an elite entry system for financial conglomerates. While the first license has yet to be issued, the market structure—dominated by state-backed players and strategic equity partners—is already firmly established.