Vietnam establishes digital technology framework and launches crypto asset market pilot program

9 October 2025

Vietnam’s new Law on Digital Technology Industry (“Law”) will come into force from 1 January 2026, with certain provisions having taken effect on 1 July 2025. Passed by the National Assembly in June 2025, the Law provides a comprehensive framework for the digital technology sector. The provisions that are effective from July 2025 focus on funding and investment incentives to jumpstart the industry, ensuring that support for enterprises and startups is available ahead of full implementation.

The Law seeks to position Vietnam as a competitive player in the global digital economy by fostering innovation, supporting research and development (“R&D”), and encouraging both domestic and foreign investment. It introduces Vietnam’s first comprehensive legislative framework designed to promote and regulate the development of the digital technology industry, defined as an economic sector based on science, technology, and innovation to create digital products and services. The Law encompasses both the production of digital technology products including semiconductors, artificial intelligence (“AI”), and digital assets.

Separately, on 9 September 2025, the Government launched a five-year pilot program (“Pilot Program”) for Vietnam’s crypto asset market through Resolution 05/2025/NQ-CP (“Resolution”) providing, for the first time, a formal legal framework for the issuance, trade, and management of crypto assets.

This article summaries some of the key aspects of these changes to Vietnam’s digital framework.

Law on Digital Technology Industry

The Law applies to all domestic and foreign agencies, organisations, and individuals engaged in or related to the digital technology industry in Vietnam. It regulates the development and deployment of digital technologies with the exception of activities conducted solely for national defence, security, and cryptography. The “Make in Viet Nam” digital technology program is also given statutory footing to promote domestic capabilities and exports.

Digital assets

Digital assets, crypto assets, and cryptocurrencies are formally recognised in the Law, not only protecting legitimate ownership rights but also clarifying the legal framework for businesses operating digital infrastructure. “Digital assets” are defined as assets under the Civil Code represented in digital form, created, issued, stored, transferred, and authenticated by digital technology in the electronic environment. Securities, digital forms of legal tender, and other financial assets as prescribed by civil and financial laws are excluded from this definition.

The Law provides that State regulation of digital assets will encompass their creation, issuance, storage, transfer, and recognition of ownership rights, with oversight focused on cybersecurity and anti-money laundering and counterterrorism financing safeguards.

Key provisions on AI

The Law sets out governance principles on the use of AI while also establishing mandatory identification marking for AI systems and AI-generated products. AI systems are defined as machine-based systems designed to operate with various levels of autonomy and adaptability which process input data to generate predictions, content, recommendations, or decisions that may affect the physical or digital environment.

AI systems that interact directly with people must notify users that they are AI-generated except where it is evident to the user. Digital products designated under an official government list as being created by AI must carry clear identification labels, both visible to humans and recognisable to machines. The Ministry of Science and Technology will publish and manage this list and enforce compliance.

Risk classification

The Law introduces a risk-based regulatory model. “High-risk” AI systems - that is, those posing potential harm to human health, rights, public interests, or social order - face enhanced oversight. So do “large-impact” systems, characterised by wide-scale use, extensive data volumes, or large model parameters. For these, developers must meet technical, transparency, cybersecurity, and governance requirements, subject to ongoing State supervision.

Incentives and State support

The Law provides a range of preferential measures to accelerate digital industry growth, including:

  • Financial resources: To underpin development of the sector, the Law provides multiple funding streams - from the State budget, investment and innovation funds, and enterprise-level technology development funds - to be allocated and managed by the Government.
  • Investment incentives: Particularly preferential treatment is afforded to projects in areas such as software development, AI systems, semiconductor chip design and testing, and AI data centres. These projects will benefit from enhanced tax, land, investment, and customs incentives.
  • Startup support: Innovative digital technology startups are granted similar preferential status, with access to direct local budget support and funding under the Digital Technology Industry Development Program. This may cover talent development, R&D, pilot production, consulting, and technology acquisition.
  • Workforce incentives: High-quality personnel working on key projects such as semiconductor chips, AI systems, and training will enjoy a five-year personal income tax exemption on income derived from qualifying activities in concentrated digital technology zones.

These preferential measures apply equally to foreign-invested enterprises.

Resolution 05/2025/NQ-CP

The Resolution provides for the inception of the Pilot Program relating to the offering and issuance of crypto assets, organisation of the crypto asset trading market, provision of crypto asset services, and State management of the crypto asset market in Vietnam.

Application

The Pilot Program applies to the following entities and individuals (collectively, “Participants”):

  • Organisations providing crypto asset services (“Service Provider”);
  • Organisations issuing crypto asset (“Issuer”);
  • Vietnamese organisations and individuals and foreign organisations and individuals participating in crypto asset investment and operating in the crypto asset market in Vietnam within the scope of the Resolution; and
  • Other agencies, organisations, and individuals related to the offering and issuance of crypto assets, organisation of crypto asset trading markets, and the State management of the crypto asset market in Vietnam.

Key definitions

The definition of “digital assets” in the Resolution mirrors the definition employed by the Law which is set out above. In addition, the Resolution defines crypto assets as a type of digital asset that uses encryption technology or digital technology with similar functions to authenticate assets during the process of creation, issuance, storage, and transfer. Crypto assets do not include securities, digital forms of legal currency, and other financial assets as prescribed by civil and financial laws.

Pilot Program principles

The Resolution sets out guiding principles for the Pilot Program, including the following:

  • The Pilot Program must be implemented with caution and under strict control, following a phased roadmap aligned with practical conditions. It must ensure safety, transparency, efficiency, and protection of the legitimate rights and interests of organisations and individuals participating in the crypto asset market.
  • All activities under the Pilot Program must comply with Vietnamese law and with international treaties to which Vietnam is a party.
  • Foreign investors participating in Vietnam’s crypto asset market must comply with both Vietnamese law and the laws of their country of establishment, operation, or citizenship, unless those foreign law provisions conflict with the fundamental principles of Vietnamese law or with international treaties to which Vietnam is a party.
  • Participants are responsible for ensuring that all published information is accurate, truthful, complete, timely, and not misleading. They must comply with regulations on issuance, trading, information management, and permitted purposes of use for crypto assets.
  • All offering, issuance, trading, and payment transactions involving crypto assets must be conducted in Vietnamese Dong.

Offering and issuance of crypto assets

The Issuer must satisfy the following requirements to offer and issue crypto assets:

  • Be a Vietnamese enterprise, registered to operate as a limited liability company or a joint-stock company under the Law on Enterprises; and
  • Crypto assets must be issued based on underlying assets that are real assets, excluding assets that are securities or legal currencies.

Crypto assets can only be offered and issued to foreign investors and may only be traded between foreign investors through a licensed Service Provider.

Crypto assets trading market organisation

The Resolution provides that domestic investors who currently hold crypto assets and foreign investors are able to open accounts with a Service Provider licensed by the Ministry of Finance (“MOF”). These accounts can be used for holding, purchasing, and selling crypto assets in Vietnam.

Six months after the first Service Provider is licensed, domestic investors who trade crypto assets without going through a licensed Service Provider will be penalised with administrative sanctions or criminal prosecution.

Obtaining a licence

An enterprise must be licensed to act as a Service Provider under the Pilot Program. To qualify for a licence, the enterprise must:

  • be a Vietnamese enterprise registered to operate in the field of crypto asset-related services, in the form of a limited liability company or joint-stock company in accordance with the Law on Enterprises;
  • have a minimum paid-up charter capital of VND10,000 billion (approximately US$380,000); the charter capital contribution must be in Vietnamese Dong;
  • satisfy the following capital requirements:
    • At least 65% of the charter capital must be contributed by institutional shareholders or members. More than 35% of this must be contributed by at least two institutions that are commercial banks, securities companies, fund management companies, insurance companies, or technology enterprises;
    • Institutional shareholders or members must have legal entity status and must have operated profitably for the two consecutive years preceding the licence application. Their financial statements for those two years must be audited with unqualified audit opinions;
    • Each enterprise or individual can only contribute capital to one Service Provider licensed by the MOF; and
    • The total capital contribution or shareholding by foreign investors must not exceed 49% of the enterprise’s charter capital.
  • have a physical office, adequate infrastructure, technical systems, office equipment and technology systems suitable for providing crypto asset services;
  • meet the specific personnel requirements for specific roles in the enterprise as set out in the Resolution. For example, the general director must have at least two years of experience working in operational departments of organisations in the fields of finance, securities, banking, insurance or fund management;
  • implement processes relating to stipulated areas, including risk management and information security, and customer asset custody and management; and
  • have an information technology (“IT”) system that meets level 4 IT system security standards as prescribed by law before being put into operation.

Enterprises that meet these requirements are able to apply for Service Provider licenses via the procedure set out in the Resolution. Applications are filed with the MOF, which will coordinate with the Ministry of Public Security, and the State Bank of Vietnam. A decision on the application is to be issued within 30 days. Successful applicants must begin operations as Service Providers within 30 days of approval.

Money transfers by foreign investors

Foreign investors must open a dedicated Vietnamese Dong-denominated account at a licensed Vietnam bank to carry out receipt and payment transactions related to the purchase and sale of crypto assets in Vietnam.

Termination of Pilot Program

The MOF is able to recommend the temporary suspension or termination of the Pilot Program if risks arise that affect the security and safety of the financial and monetary markets, social order, or public interests to ensure the “harmony of interests between the State, investors and enterprises”.

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