Key Summary

Vietnam's new regulatory framework sets an extremely high barrier to entry, with only large banks, securities companies, or global exchanges with strong partners likely to meet the standards.

Although seven local companies have made early moves, most lack sufficient capital strength and institutional qualifications, making it difficult for them to meet regulatory requirements.

Binance and Bybit have been received by high-level Vietnamese government officials, indicating that foreign exchanges will share the market pie with a few licensed local institutions.

1. A New Regulatory Era: Vietnam's Digital Asset Market Moves Towards Standardization
   In 2025, Vietnam's digital asset market underwent a decisive transformation. After years of regulatory ambiguity, the government successively introduced three major policy frameworks, marking the country's official transition from a laissez-faire "gray area" to a new stage of comprehensive regulation and controllable taxation.

The primary cornerstone is the "Digital Technology Industry Law" passed by the National Assembly in June 2025, set to take effect on January 1, 2026. This law, for the first time, explicitly defines the independent status of digital assets at the legal level, distinguishing them from securities and legal currency instruments, providing the legal basis for subsequent taxation, anti-money laundering supervision, and law enforcement authority. Specific details will be further clarified through implementing regulations.

The second key initiative is the "Regulatory Sandbox Decree" effective July 1, 2025. Led by the State Bank of Vietnam, this sandbox mechanism provides a testing environment for financial innovation. Although not specifically designed for cryptocurrency, through core requirements such as anti-money laundering, customer identity verification, and settlement, it is expected to form regulatory synergy with the exchange licensing system. The most immediately impactful is Resolution No. 05/2025/NQ-CP promulgated on September 9, 2025, officially launching a five-year pilot for virtual asset issuance and trading. This became the first practical framework for exchanges to operate legally in Vietnam. A key limitation is that during the pilot phase, only Vietnamese local enterprises can apply for operator licenses; foreign exchanges must participate indirectly through joint ventures or by providing technology, compliance systems, and liquidity support.

This series of measures demonstrates the government's intent: to gradually bring digital asset activities into the domestic system under strict supervision. The policy direction clearly favors local control, aligns with international anti-money laundering standards, and is deeply tied to the strategic goal of building Da Nang into a regional financial center.

For institutions, the core point is that Vietnam has bid farewell to the era of regulatory vacuum, which is a positive signal. However, the high licensing thresholds and foreign investment restrictions indicate that the degree of openness remains limited. The next 12-18 months will witness whether Vietnam can grow into a structured market or merely remain a policy testing ground.

2. The High Threshold for Licensed Operation
   Resolution No. 05/2025/NQ-CP issued on September 9, 2025, sets stringent entry conditions for Vietnam's five-year cryptocurrency pilot: only enterprises registered under the "Enterprise Law" in Vietnam are eligible to apply for operator licenses.

Licensed institutions must maintain a minimum legal capital of 10 trillion VND (approximately USD 380 million), which must be fully paid up in Vietnamese Dong. At least 65% of this capital must come from institutional shareholders, and within that portion, over 35% must be jointly contributed by at least two organizations of the following types: commercial banks, securities companies, fund management companies, insurance companies, or technology enterprises. Institutional shareholders must also meet the requirement of having profitable records for two consecutive years, with their audited financial reports receiving unqualified opinions.

Foreign ownership is strictly limited to within 49% of the legal capital, ensuring operational control remains with local entities. Furthermore, licensed institutions must meet strict human resources and infrastructure requirements: the CEO must have at least two years of experience in the financial industry, the CTO must have five years of relevant IT experience, and the institution must employ at least 10 staff with cybersecurity certifications and 10 with securities practice qualifications. The technical system must achieve the Level 4 National Information Security certification, the highest standard in the financial industry.

Although this framework demonstrates the government's determination to regulate the market, its requirements pose challenges even for mature financial institutions. If the scope of application is extended in the future to include wallet services, GameFi projects, or medium-sized exchanges, the vast majority of native crypto enterprises will struggle to meet the standards.

It is worth noting that local Vietnamese projects like KyberSwap and Coin98 have proactively suspended domestic operations. In practice, a hybrid model is most likely to form: banks, securities firms, insurance companies, and tech giants form the licensed core, while Web3 projects participate as technology and service providers. In this shift, market dominance will tilt towards licensed institutions, potentially marginalizing startups and native crypto projects.

Business scope is also strictly limited: only asset-backed token issuance and spot trading are permitted, and settlements must use Vietnamese Dong. Cryptocurrency payment functions remain prohibited, and derivatives and leverage trading are not yet open. Compared to pioneers like the US, Singapore, and Hong Kong, Vietnam's permitted business scope is significantly narrower.

3. The Confrontation Between Local and International Forces
   3.1 Local Participant Layouts
   Several Vietnamese enterprises have prepared in advance by registering "digital asset exchange" entities, hoping to gain a first-mover advantage after the new policy takes effect. However, the current capital scale and ownership structure of these institutions still fall far short of the hard requirements of Resolution 05/2025.

For institutional investors, three observations are noteworthy. First, the capital gap is decisive. The capitalization levels of all current participants range from 20 billion VND to 1.47 trillion VND, far below the statutory minimum requirement of 10 trillion VND. Without large-scale capital injections from banks, securities companies, or insurance companies, most of these entities will not qualify for licenses.

Second, institutional anchoring will determine who survives. The resolution requires at least 65% institutional ownership, including a 35% share from at least two banks, securities companies, insurance companies, or technology enterprises. This clause clearly favors participants already connected to major financial institutions like SSI, VIX, Techcom, HD, and MB, while putting fintech-led vehicles like DNEX or CAEX at a disadvantage, unless they can attract stronger partners.

Finally, market expectations suggest licenses will be limited. Rumors indicate that no more than five operators will be approved in the initial phase. With at least seven contenders already positioning themselves, some are bound to be excluded. For global exchanges assessing the Vietnamese market, this increases the importance of aligning early with the most credible domestic partners.

3.2 Global Players and Government Strategic Interaction

Global exchanges are actively building communication bridges with the Vietnamese government. On September 24, 2025, during an official visit to the UAE, Standing Deputy Prime Minister Le Thanh Long met with Binance CEO Richard Teng. The Deputy Prime Minister invited Binance to establish a regional headquarters in Da Nang and participate in building a licensed digital asset exchange for Vietnam's International Financial Centre. He also invited Teng, former head of Abu Dhabi Global Markets, to serve as a senior advisor for the Vietnam Financial Centre. This move, announced through official government channels, sent a clear policy signal.

Concurrently, the Da Nang People's Committee signed a Memorandum of Understanding (MoU) with Binance, establishing strategic cooperation in blockchain and digital assets. This means Binance has both high-level endorsement and a local government cooperation framework.

Bybit is also on the offensive. On September 17, 2025, it signed a tripartite MoU with the Da Nang People's Committee, the Abu Dhabi Blockchain Center, and Verichains. The cooperation covers liquidity provision, infrastructure security, and ecosystem connectivity, precisely aligning with Vietnamese regulatory objectives. Although not reaching the level of Binance's high-level meeting, it lays a practical foundation for its participation in the International Financial Centre construction.

The current landscape shows that Binance and Bybit have taken the lead in the race among global exchanges for Vietnam. If, as rumored, only 5 licenses are issued, and 2 of them are reserved for international exchanges, then local companies are left with only 3 spots. Facing at least 7 eager competitors, local institutions must accelerate efforts to prove their strength and institutional background to secure the remaining seats.

This layout also triggers a chain of thought: What will happen to global exchanges like BingX and MEXC, which already dominate Vietnam's retail market? These exchanges serving Vietnamese users through offshore platforms risk being marginalized in the licensed market if they fail to conduct government relations promptly. Unless they quickly form alliances with approved local entities or receive special invitations, their businesses will continue to operate outside regulation, potentially facing regulatory risks once the licensed market matures.

4. Strategic Breakthrough: The Entry Path for the "CEX Tiger" Hypothetical Case
   Under the new system, what options are available for projects seeking to enter Vietnam? Consider a hypothetical case, "CEX Tiger," a global exchange planning to expand into Vietnam, and which strategies would be most feasible.

The first and most important decision is partner selection. Foreign exchanges cannot obtain licenses directly and must ally with strong domestic institutions. Identifying which Vietnamese banks, securities companies, or insurance companies are most likely to obtain one of the limited licenses is crucial. The choice of partner will determine market access, compliance posture, and long-term scalability.

Once a partner is secured, the next step is defining the operational model. A hybrid structure is needed: the Vietnamese partner holds the license and regulatory responsibility, while CEX Tiger contributes technology, liquidity, and operational expertise. A joint venture becomes the formal entity, with the domestic institution serving as the legal and regulatory front, and the foreign exchange running the underlying services.

Business expectations must also be calibrated. The framework limits activities to spot trading, VND settlement, and limited investor participation. This is not a market designed for immediate trading volume or derivatives-driven revenue. Instead, the strategic goal should be to secure an early presence, build regulatory goodwill, and establish legitimacy ahead of potential future liberalization.

However, competition will be fierce. If two licenses are allocated to Binance and Bybit, only three remain for domestic institutions. For latecomers, the real question is not whether Vietnam is attractive – the market's growth and user base make that obvious – but whether a credible domestic partner can be secured, and if that partner is willing to cooperate. Missing the first round of licenses could delay entry until the framework expands.

For exchanges like CEX Tiger, Vietnam should be viewed as a long-term strategic pivot rather than a short-term profit source. The key to success lies in: carefully selecting a qualified local partner, accepting a minority equity position, and diligently cultivating a presence in advance in one of Asia's most promising crypto growth markets.

Considering the user end, the challenges are more complex. Vietnamese users are accustomed to global trading platforms. Even with a license, new entrants will face multi-dimensional tests including security standards, asset variety, and platform stability. A license brings compliance but cannot automatically translate into user trust and market share.

The ultimate strategic choice lies before players like CEX Tiger: join hands with local partners in the license race, or remain on the regulatory periphery serving existing users while closely tracking policy evolution? The strategic game concerning the Vietnamese market has just begun.