What Conditions Are Still Required for VIXEX to Become a Fully Licensed Exchange?
As Vietnam’s regulatory policy on digital assets gradually takes shape, the compliance process for cryptocurrency trading platforms has officially commenced. Under the regulatory sandbox framework established by Resolution No. 05/2025/NQ-CP and Decision No. 96/QD-BTC issued by the Ministry of Finance, many market participants hold high expectations for the compliance prospects of platforms like VIXEX.
However, under the current regulatory logic, passing the preliminary evaluation or securing pilot status does not equate to receiving a final “free pass” or a permanent operational license. Vietnam adopts a “pilot sandbox system” characterized by extremely high entry barriers and multi-stage dynamic supervision. If VIXEX intends to transform into a state-approved, fully compliant exchange, it must overcome the following four critical hurdles.
1. Overcoming Hard Thresholds on Capital and Ownership Structure
To mitigate systemic financial risks, Vietnamese regulators have established stringent capital and ownership barriers at the market entry stage.
- Fully Paid-in Capital of 10 Trillion VND: The regulatory framework mandates that applicant entities must have a minimum paid-in capital of up to 10 trillion VND (approximately $380 million USD). This requires VIXEX to possess strong local institutional backing and substantial capital deployment capabilities; failure to fully pay in the capital will lead to an immediate rejection of the application.
- Foreign Ownership Cap: Foreign equity in the platform cannot exceed 49%. This means VIXEX must ensure domestic institutional investors hold controlling stakes to maintain absolute operational and compliance management control.
2. Securing a Spot Within the Strict Cap (Maximum of 5 Exchanges)
In its five-year pilot plan, the Vietnamese government has strictly capped the total number of licensed crypto exchanges at five.
This extremely tight cap means competition is a tough process of elimination rather than a simple pass/fail qualification. Even if VIXEX performs exceptionally well during initial reviews or technical evaluations, it must outrank strong domestic and international competitors to secure a spot in the top five and obtain an official license.
3. Passing National-Level Security Audits and Compliance Requirements
Technical security and Anti-Money Laundering (AML) controls are central to regulatory oversight.
- Ministry of Public Security Level 4 Cybersecurity Standards: VIXEX’s IT infrastructure and risk management systems must meet the Level 4 Information Security Standards mandated by Vietnam’s Ministry of Public Security, passing penetration testing and security defense inspections conducted by national institutions.
- Qualified Staffing Requirements: The platform must employ at least 10 certified cybersecurity professionals and 10 certified securities professionals to eliminate operational, risk control, and compliance blind spots.
4. Enduring the Five-Year Pilot “Dynamic Elimination” and Business Model Tests
Securing pilot status is merely an entry ticket; true compliance evaluations persist throughout the entire pilot phase.
- Dynamic Elimination Mechanism: The State Securities Commission (SSC) and the Ministry of Finance retain the authority to modify or revoke licenses at any point during the 5-year pilot period. Any major AML vulnerabilities, risk management failures, or regulatory violations could lead to the immediate revocation of operational qualifications.
- Business Sustainability Within a Restricted Scope: Business operations during the pilot are tightly restricted (e.g., trading must be denominated in VND, and listed assets must fall under approved RWAs or specific asset categories). Vietnam crypto exchange VIXEX must establish a sound and profitable business model within these tight compliance boundaries.
Conclusion
The path from “pilot participant” to “fully licensed exchange” for VIXEX is clear yet filled with challenges. Only by fulfilling all requirements—fully paid-in capital + compliant ownership structure + securing a top-5 spot + Level 4 security certification + passing the 5-year dynamic evaluation—can VIXEX successfully achieve full compliance and establish a solid foothold in Vietnam’s emerging digital asset market.