Vietnam’s Cryptocurrencies: Legal Framework and Market Outlook

Vietnam’s Cryptocurrencies: Legal Framework and Market Outlook


The state of Vietnam's Crypto Market

Regulatory orientation

  • Cryptocurrencies are now recognised as legitimate instruments for exchange and investment; however, they are not permitted as a mean of payment in Vietnam
  • The State Bank of Vietnam (SBV) has outlined five pillars to develop a comprehensive legal framework for cryptocurrencies, aimed at strengthening the regulatory environment
  • In the meantime, pilots are being implemented for trading and payments - licensing five crypto exchanges for digital-asset trading and allowing foreigners to use stablecoin for payments in Da Nang

Development scenarios & application

  • PwC has developed 2 scenarios in light with the official recognition of crypto’s legal status: 1) Conservative growth from a strict regulatory framework, 2) A stronger market’s growth prospects with generic/relaxed regulatory framework imposed or based on global acts
  • The success of the pilots and sandboxes will create significant potential for blockchain and crypto-based applications: advanced trading products, on/off-ramp businesses, smart contract applications, and more

Market capitalisation

  • Vietnam ranks among ASEAN leaders in crypto penetration with c.5% of the population having used crypto, second only to Singapore (c.20% penetration rate, driven by Singapore’s more advanced legalisation)
  • Total crypto holdings by Vietnamese are estimated at about USD18 billion and are projected to grow at an 18–35% CAGR to roughly USD48–109 billion, contingent on the openness of the regulatory framework

Five pillars to develop a legal framework for cryptocurrencies proposed by SBV, aiming at strengthening the regulatory environment

 

Legal status & roadmap for legalisation

  • Establish clear definitions to distinguish electronic money, virtual currency, crypto‑assets, tokens, and CBDC, aligned with international standards
  • Initiate pilot programs, roadmaps, sandboxes for crypto exchanges, custodial wallets, Initial Dex Offerings (IDOs), and evaluate the outcomes to support the creation of long-term regulations

 

 

 

Streamline management and coordination

  • Establish a government‑controlled management board with representatives from relevant Ministries to oversee construction and implementation of initiatives, ensure legal alignment, and collaborate with the international

Management, licensing and risk control 

  • Develop licensing and oversight for digital asset services in Vietnam
  • Set clear standards, including security and Anti Money Laundering (AML) measures
  • Assign roles i.e., Security tokens to the SSC, utility tokens to the Ministry of Industry and Trade (MoIT), stablecoins to the SBV
  • Include Virtual Asset Service Providers (VASPs) in AML regulations
  • Standardise consumer protection and dispute resolution measures

Education to enhance population awareness 

  • Develop educational programs on financial and technological virtual assets
  • Promote awareness about virtual assets by educating the public on investment risks, citizen rights & obligations, etc.
  • Develop training programs for law enforcement agencies

Taxation policy & CBDC 

  • Issue taxation guidelines with income from sources e.g., trading, remittance, etc. or with the VASPs
  • Construct mechanism for tracking money flow and generate tax incentives, as crypto remain a borderless concept
  • SBV recommended the 2-level CBDC model (with SBV issues / commercial banks distribute) to provide a safe means of payment

Several development scenario has been tested to illustrate the expected orientation of Vietnam crypto regulation environment

Officially recognise crypto’s legal status

Low case: Impose clear/strict regulatory framework

Base case: Impose generic/relaxed regulatory framework or based on global acts

Scenario description

Crypto exchanges is permitted with defined compliance terms & conditions for transactional limits, AML, tax schemes, VASPs, etc.

Crypto exchanges is permitted with general and minimal crypto-specific limitations, supported by international cross-border regulatory frameworks

Scope coverage

Banks, PSPs, crypto exchanges, stock companies, etc. with VASP licenses (domestic prioritised) authorized by the government

Competitive participation from foreign/international financial institutions, PSPs, crypto exchange players

Compliance & fraud protection

High: Custodian may have to be performed through licensed VASPs

Medium to low: Can allow self-custody wallets & decentralised storage

Government stance

Prioritise maintaining strict control of capital flows, protections for key stakeholders and maintaining the current economy openness & stability

Prioritise maximising economic benefits from capital cross-border flows, improving the economy openness

Impact on investors

 

  • Limit capital inflows and reduce crypto’s appeal
  • Attract new retail investors, however slow growth and limited wealth participation
  • Limits product breadth. Institutions may participate chiefly for incremental diversification rather than return-seeking exposure
  • Attract capital, boost digital economy, and enhance crypto’s appeal
  • Enhance market penetration and wealth participation
  • Enhance product breadth with derivative product offerings, deeper penetration from institutions

Implications

Prioritises stability and fraud protection but sacrifices capital inflows and investors enthusiasm. Market growth remains limited, slowing integration with global crypto ecosystems

Attracts significant capital, accelerates digital economy growth, and deepens investor participation. However, this introduces higher compliance and systemic risk exposure

Let's navigate complexity with confidence, together.

What Services does PwC provide around Digital Assets?

Using human-led and tech-powered approach and experiences, our Digital Assets help clients navigate this ecosystem and build the solutions they need to tackle today’s challenges.

We serve a wide range of Service Providers, including crypto exchanges & custodian, payment processors, digital asset banks, financial institutions, token issuers, central banks, governments, regulators & policy makers, and others.

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Vietnam’s Cryptocurrencies: Legal Framework and Market Outlook

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Get in touch

Nguyen Luong Hien

Partner, Deals/Strategy, PwC Vietnam

Tel: +84 28 3823 0796

Dieu Tue Nhung

Director, Deals/Strategy, PwC Vietnam

Tel: +84 28 3823 0796

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