Crypto Exchange License Qualifier
Check if your organization qualifies for Vietnam's 2025 licensed crypto exchange license under Resolution No. 05/2025/NQ-CP. Requirements include:
- Minimum 10 trillion VND ($379 million) capital
- 2+ years of consistent profit
- Backing from commercial banks, securities firms, insurance, or major tech
- Physical headquarters in Vietnam
Licensing Requirements
According to Vietnam's 2025 regulations:
- • Minimum capital: 10 trillion VND ($379 million USD)
- • Must be backed by established financial institutions or tech giants
- • Requires two consecutive years of positive profit
- • All trading must occur in Vietnamese Dong (VND)
For years, the State Bank of Vietnam (SBV) made it clear: cryptocurrency was off-limits. Banks couldn’t process crypto transactions. People couldn’t use Bitcoin to pay for goods. Even holding digital assets was legally gray. But in 2025, everything changed. Vietnam didn’t ban crypto - it regulated it. And the rules are unlike anything else in Southeast Asia.
From Ban to Bureaucracy: The 2025 Shift
In June 2025, Vietnam passed the Law on Digital Technology Industry, officially recognizing Bitcoin and Ethereum as "virtual assets." This wasn’t a green light for free trading. It was a controlled opening. The SBV didn’t want to lose control of its monetary system. So instead of letting crypto run wild, it built a cage - and made sure only a few could enter.
The real turning point came in September 2025 with Resolution No. 05/2025/NQ-CP. This wasn’t just a guideline. It was a legal framework with teeth. Crypto exchanges now need a license. And getting one isn’t easy. You need at least 10 trillion Vietnamese dong in capital - roughly $379 million. That’s more than most regional exchanges have in total. And you can’t just be any company. You need to be backed by established players: commercial banks, securities firms, insurance companies, or major tech enterprises. Plus, those backers must have shown two straight years of profits.
Only Five Exchanges Allowed - And Only in Dong
The SBV isn’t trying to compete with Binance or Coinbase. It’s building its own version of a crypto market - one that answers to Hanoi. The pilot program allows only five licensed exchanges to operate. And here’s the kicker: all trading must happen in Vietnamese dong (VND). No USDT. No BTC/USD pairs. If you want to buy Bitcoin, you have to convert your VND first. Foreign investors can’t trade directly either. They must go through Ministry of Finance-approved Crypto Asset Service Providers (CASPs).
This structure forces all crypto activity to flow through Vietnam’s financial system. Every transaction leaves a paper trail. Every exchange is monitored. And every dollar of profit is subject to Vietnamese tax law. The goal? Keep control. Prevent money laundering. Stop capital flight. And make sure digital assets serve the local economy, not bypass it.
Why No One Has Applied Yet
As of October 2025, not a single company has submitted a license application. That’s not a sign of disinterest. It’s a sign of fear. The capital requirement alone is a wall. Most local fintech firms don’t have $379 million lying around. Even big banks are hesitant. The compliance burden is massive. You need real-time monitoring, KYC for every user, audit trails for every trade, and a physical headquarters in Vietnam. For many, it’s easier to wait - or keep operating in the shadows.
Meanwhile, informal trading is booming. Binance P2P is one of the most active markets in Vietnam. People trade Bitcoin for VND through peer-to-peer deals, cash deposits, or even mobile wallets. The SBV knows this. It just doesn’t have the tools to stop it. That’s the tension right now: a strict legal framework on paper, and a thriving underground market in practice.
NDAChain: Vietnam’s Own Blockchain
While the public crypto market stalls, the government is quietly building something else: NDAChain. Launched in July 2025, this is a permissioned blockchain - meaning only approved entities can join. It’s not for Bitcoin or Ethereum. It’s for bonds, carbon credits, land titles, and government certificates. Think of it as Vietnam’s digital notary system. The state controls every node. Every transaction is logged. No anonymity. No decentralization. Just efficiency - with oversight.
NDAChain shows the SBV’s real priority: not crypto freedom, but state control over digital innovation. They want the benefits of blockchain - faster settlements, reduced fraud, better data - without giving up power. It’s a classic central bank move: adopt the tech, but keep the leash.
High Adoption, Low Access
Vietnam ranks fourth in the world for crypto adoption, according to Chainalysis 2025. Over 20% of its tech-savvy population owns digital assets. That’s higher than the U.S. or Japan. But here’s the paradox: most of these people can’t legally trade on a licensed exchange. They’re using P2P platforms, overseas apps, or even Telegram bots. The SBV didn’t stop adoption - it just made it harder, riskier, and less transparent.
Some analysts think this will backfire. If young investors can’t access regulated markets, they’ll keep using unregulated ones. And if those platforms get hacked or shut down, the victims won’t have legal recourse. The SBV’s stance protects the banking system - but not the people.
What’s Next? The Five-Year Clock
The entire crypto framework is a five-year pilot. That means everything could change in 2030. The SBV is watching. Is tax revenue rising? Are banks starting to participate? Is capital flowing into local projects? If yes, they might loosen rules. If not, they might shut it down or make it even stricter.
One thing is certain: the SBV isn’t rushing. Unlike Singapore, which welcomed stablecoins and institutional crypto, Vietnam is moving like a chess player - one slow, calculated move at a time. They’re not trying to be the next crypto hub. They’re trying to be the most controlled one.
Who Benefits?
Right now, the biggest winners are the government and the few financial giants who might eventually get a license. The state gets tax revenue, better data, and control over capital flows. The big banks get a monopoly on crypto trading - no foreign competitors allowed. The average investor? They get fewer choices, higher risk, and no legal protection if things go wrong.
But there’s a silver lining. For the first time, Vietnamese citizens can legally own, inherit, and transfer crypto assets. That’s a huge step forward. Before 2025, holding Bitcoin was a legal gray area. Now, it’s a recognized asset. That means courts can enforce ownership. That means people can leave crypto to their kids. That’s real progress - even if the system is still tightly locked down.
The Bigger Picture
Vietnam’s approach is a warning to other countries. You don’t have to ban crypto to control it. You can make it so expensive, so complicated, and so restricted that only the state and its allies can play. It’s not freedom. It’s managed innovation.
For investors, the message is simple: don’t expect quick gains. Don’t assume regulation means safety. And don’t trust that a licensed exchange will be easy to find - because right now, none exist. The real opportunity isn’t in trading. It’s in watching how Vietnam balances control and growth. Because if they get it right, they might just become the model for how authoritarian economies handle digital money - without losing power.
Reggie Herbert
December 4 2025The SBV didn't regulate crypto-they weaponized bureaucracy. $379 million capital requirement? That's not a barrier to entry, it's a class filter. Only state-aligned conglomerates get to play, while ordinary people are forced into P2P shadows. This isn't innovation-it's financial apartheid dressed in compliance jargon.