Vietnam's Crypto Assets legislation undergoes a fundamental transformation: officially recognized as legal property under civil law.

Author | FinTax

Introduction

For a long time, Vietnam's legal definition of cryptocurrency has been unclear, and tax policies have also fallen into a "gray area," leaving market participants shrouded in uncertainty. However, this situation underwent a significant change on June 14, 2025, when the National Assembly of Vietnam passed the "Law on Digital Technology Industry," which officially incorporates crypto assets into the national legal framework with clear classification and regulation, formally granting them legal status and marking a milestone in the country's cryptocurrency regulatory process.

The new law classifies digital assets into two categories: "virtual assets" and "cryptographic assets," excluding financial instruments such as securities and digital fiat currencies, while granting the government the authority to formulate implementation rules. It also emphasizes strengthening requirements for cybersecurity, anti-money laundering, and counter-terrorism financing. This law is set to take effect on January 1, 2026, with the core objective of improving the relevant legal framework, aligning with international regulatory standards, and assisting Vietnam in expediting its exit from the FATF gray list.

This article will attempt to analyze the legislative breakthrough's role in restructuring Vietnam's digital economy landscape, examining the latest dynamics and future trends of its tax system. By outlining the evolution of the Vietnamese government's policies over the past few years from cautious observation to actively building a regulatory framework, a comparative analysis will be conducted with the practices of other representative countries in Southeast Asia and globally in the field of cryptocurrency taxation and regulation. Furthermore, it will also look ahead to Vietnam's strategies in balancing risk prevention and innovative development, predicting specific policies that may be introduced in the coming years, as well as the potential impact of these policies on Vietnam as an emerging digital economy.

1 Vietnam clarifies the legal status of crypto assets

Before the promulgation of the Digital Technology Industry Law, Vietnam's legal characterization of cryptocurrencies had been in a vague and constantly evolving state. Initially, the Vietnamese government's attitude towards cryptocurrencies was mainly reflected in strict restrictions and risk warnings regarding their use as a means of payment. For example, the State Bank of Vietnam (SBV) explicitly stated in its official document 5747/NHNN-PC released in July 2017 that cryptocurrencies such as Bitcoin and Litecoin are not recognized as legal tender or means of payment in Vietnam and explicitly prohibited their issuance, supply, and use, with violators potentially facing administrative or criminal sanctions. Subsequently, in April 2018, the Prime Minister issued Directive 10/CT-TTg, requiring relevant departments such as the General Statistics Office, the Ministry of Finance, and the Ministry of Public Security to strengthen the management of cryptocurrency-related activities, aiming to enhance control over related transactions and prevent potential harm.

Although the Ministry of Finance announced in its official letter 4356/BTC-TCT in April 2016 that it does not prohibit cryptocurrency trading and defined it as "property" and a liquid "commodity", the lack of clear legislative support has led to ambiguity in the actual implementation of this directive, making compliance and enforcement related to cryptocurrency trading relatively complex. Furthermore, according to Article 105.1 of the Vietnamese Civil Code of 2015, assets are defined to include various items, money, monetary instruments, and property rights, but digital assets such as cryptocurrencies clearly do not fall into any of these categories; thus, under current Vietnamese law, these assets themselves are not considered physical assets. This lack of classification has created significant legal gaps, directly impacting the treatment and regulation of these assets within the legal framework.

However, this ambiguous status underwent a fundamental change on June 14, 2025. The National Assembly of Vietnam passed the landmark "Law on Digital Technology Industry," which will officially take effect on January 1, 2026. This law clearly defines "digital assets" for the first time in the Vietnamese legal system and further categorizes them into "cryptographic assets" (secured by cryptography and blockchain technology) and "virtual assets" (primarily used for trading and investment, but excluding securities, stablecoins, and central bank digital currencies). This legislative breakthrough ended years of uncertainty regarding the legal status of cryptographic assets in Vietnam, formally recognizing cryptographic assets as legal property under civil law, thereby providing a solid legal foundation for individuals and organizations to legally establish and exercise property rights.

This strategic shift from "non-recognition" to "legalization" is not accidental, as the Vietnamese government has recognized the enormous potential of the crypto economy. Despite regulatory obstacles, Vietnam has one of the highest cryptocurrency ownership rates in the world, ranking fifth globally, with about 20.95% of the population holding crypto assets, and annual inflows exceeding $100 billion. At the same time, Vietnam also faces the need to respond to international anti-money laundering (AML) and counter-terrorism financing (CTF) pressures, as it has been placed on the gray list by the Financial Action Task Force (FATF), which requires it to strengthen virtual asset management. Therefore, legalization is a necessary prerequisite for attracting investment, promoting the development of the digital economy, and effectively regulating this emerging industry. This indicates that the Vietnamese government has shifted from mere risk prevention to actively embracing the opportunities brought by the digital economy, and is attempting to guide and regulate this emerging industry by establishing a sound legal framework, rather than simply suppressing it.

2 The shift in Vietnam's cryptocurrency regulatory framework

Vietnam's official attitude towards the qualification of cryptocurrencies reflects a significant change in its regulatory system. In the past, Vietnam's cryptocurrency regulatory framework was characterized by inadequacies and a passive response, often employing a one-size-fits-all regulatory approach. However, with the rise of the global cryptocurrency wave and changes in Vietnam's leadership, the current cryptocurrency regulatory system is rapidly improving. It has not only formed a preliminary regulatory division structure but is also actively advancing discussions and implementations of multiple regulatory pilot projects, aiming to effectively tackle challenges such as anti-money laundering (AML) and counter-terrorism financing (CFT) while embracing new technologies.

2.1 Evolution of the Regulatory Framework

Vietnam's cryptocurrency regulatory framework has undergone a significant evolution from non-existence to active guidance.

From 2016 to 2022, Vietnam's cryptocurrency regulatory framework has transitioned from non-existent to established, moving from a one-size-fits-all approach to a stage of exploration and research.

In April 2016, a public letter from the Ministry of Finance announced that it would not prohibit cryptocurrency trading, but the definition was vague. Subsequently, in July 2017, the State Bank of Vietnam (SBV) explicitly prohibited cryptocurrencies such as Bitcoin from being used as a means of payment, emphasizing their illegality. In April 2018, the Prime Minister issued a directive requiring strengthened management of activities related to cryptocurrencies, while the SBV also instructed financial institutions to enhance measures related to cryptocurrency trading, reflecting the government's early cautious and risk-averse stance.

In May 2020, the Prime Minister instructed the SBV to launch a pilot project to explore the use of blockchain in cryptocurrencies and requested an assessment of the pros and cons of cryptocurrencies. In March 2022, the Vietnam Blockchain Association (VBA) was established, becoming the first legal entity in Vietnam focused on crypto assets, tasked with creating and nurturing a framework for the development of cryptocurrencies. That same year, Vietnam passed anti-money laundering (AML) legislation, which took effect in 2023, requiring institutions providing payment services to implement know your customer (KYC) measures, marking an important step in its international compliance efforts. In October 2022, the Prime Minister once again called for regulation of cryptocurrencies, reflecting the government's urgent need for standardization in this field.

After 2023, especially following the high-level changes in Vietnam in 2024, Vietnam's regulatory attitude towards cryptocurrencies has gradually softened.

In February 2024, the Prime Minister issued Decision No. 194/QD-TTg, instructing the Ministry of Finance to draft a legal framework for virtual assets, demonstrating the government's determination at the legislative level. In October of the same year, the Prime Minister signed Decision No. 1236/QD-TTg, promulgating the "National Strategy for the Development and Application of Blockchain Technology in Vietnam by 2025," with a vision for 2030, aiming to make Vietnam a regional leader in blockchain innovation. The strategy clearly positions blockchain as a core pillar of digital transformation and emphasizes "Made in Vietnam" blockchain platforms, indicating that the government sees blockchain and digital assets as important drivers for the development of the national digital economy.

In June 2025, the "Digital Technology Industry Law" was passed, which establishes a tolerant and prudent regulatory framework from various aspects, including clarifying the classification of digital assets (crypto assets, virtual assets), mandating the implementation of anti-money laundering (AML) and counter-terrorism financing (CTF) measures, introducing a licensing system, and providing incentives for emerging technologies such as artificial intelligence, semiconductors, and advanced computing, thereby promoting the broader development of the digital economy.

The maturation of the regulatory framework from "passive response" to "active guidance" is a key feature of Vietnam's policy evolution in the digital asset sector. Initially, Vietnam's regulation of cryptocurrencies was mainly about "prohibiting their use as a means of payment" and "risk warnings," which represented a passive and preventive stance. However, in the past two years, from the Prime Minister's directive for research, the establishment of a blockchain association, to the promulgation of the "Law on Digital Technology Industry" and the national blockchain strategy, the regulatory focus has clearly shifted towards actively constructing a framework that incorporates crypto assets into the national digital economy development strategy. This marks a more mature and pragmatic stage in Vietnam's digital asset regulation, where the goal is no longer merely to control risks, but to unleash innovation potential by establishing a clear and predictable legal environment, attracting domestic and foreign investment, and enhancing its position in the global digital economy.

2.2 Overview of the Existing Regulatory Framework and Division of Responsibilities in Vietnam

Vietnam's current cryptocurrency regulatory framework is mainly managed by various ministries, forming a pattern of "loose regulation." Multiple key institutions, including the State Bank of Vietnam (SBV), the Ministry of Finance (MoF), the Ministry of Public Security, and the Vietnam Blockchain Association (VBA), work together to construct and improve the regulatory framework, with specific responsibilities outlined in the table below.

2.3 Regulatory Sandbox Pilot and Risk Compliance Construction Under the New Normal

In order to explore the innovative applications of digital assets under the premise of controllable risks, the Vietnamese government has actively introduced regulatory sandbox mechanisms and pilot projects.

The Vietnamese government is discussing the establishment of regional and international financial centers, one key aspect of which is the introduction of a controlled testing policy (sandbox) for financial technology (Fintech), particularly targeting business models involving crypto assets and cryptocurrencies. This sandbox mechanism allows for small-scale testing of new financial technologies and business models in a controlled environment, thereby assessing their potential risks and benefits before widespread promotion. For example, Da Nang has been authorized to pilot special mechanisms, including a project using stablecoins (USDT) for international tourist payments, which is seen as an important attempt to explore the application of digital payments in the tourism industry. These pilot projects aim to accumulate practical experience to provide data and basis for a more comprehensive regulatory framework in the future.

In addition, Vietnam is actively exploring the research and development of Central Bank Digital Currency (CBDC) — the digital dong. The Prime Minister of Vietnam has repeatedly called for the State Bank of Vietnam (SBV) to study the pros and cons of digital currency and to initiate pilot cryptocurrency projects based on blockchain. Although the issuance of the digital dong is still in the evaluation stage, its potential legal status and complementary role to the traditional financial system are important components of Vietnam's digital economic development.

Of course, while promoting innovation in the regulatory framework, anti-money laundering (AML) and counter-terrorist financing (CTF) compliance remains a core concern for the Vietnamese authorities, especially after being placed on the gray list by the Financial Action Task Force (FATF).

Vietnam is currently still on the Financial Action Task Force (FATF) "increased scrutiny list" (grey list), mainly due to its shortcomings in anti-money laundering practices related to cryptocurrency. Being placed on the grey list means that the country has strategic deficiencies in combating money laundering and terrorist financing, which may affect its international financial reputation and ability to attract foreign investment. To be removed from the grey list, Vietnam must develop virtual asset management policies and strengthen relevant law enforcement.

The passage of the "Digital Technology Industry Law" is an important measure for Vietnam to respond to FATF pressure. The law clearly requires all digital asset activities to strictly implement anti-money laundering (AML) and counter-terrorism financing (CTF) measures to enhance security and transparency. This means that future cryptocurrency exchanges and related service providers must comply with global standards such as KYC and AML, and may be required to maintain compensation funds to protect users from cyber attacks, thereby reducing the risk of financial crime.

3 Vietnam cryptocurrency tax policies and their latest developments

The evolution of Vietnam's cryptocurrency tax policy has almost coincided with its regulatory policies on cryptocurrency. In the early days, due to the ambiguous and contradictory characterization of cryptocurrency by Vietnamese authorities, the regulatory approach was rough and one-size-fits-all, making it unrealistic to impose taxes on cryptocurrencies. However, the rapid expansion of cryptocurrency trading volumes forced the government to confront their legal status, compelling Vietnamese authorities to conduct research on cryptocurrencies. Especially entering 2024, the government has shown a stronger urgency in establishing a clear legal framework.

3.1 Currently, cryptocurrency trading in Vietnam is still in a tax gray area

For a long time, due to the lack of clear legal definitions and regulatory frameworks, cryptocurrency trading in Vietnam has been in a tax gray area. As mentioned above, the Vietnamese Ministry of Finance's official letter 4356/BTC-TCT in 2016, while not prohibiting cryptocurrency trading and defining it as "property" and "goods," did not address specific tax regulations. Additionally, the State Bank of Vietnam (SBV) clearly stated in its official letter 5747/NHNN-PC in 2017 that it does not recognize cryptocurrencies like Bitcoin as a means of payment, further exacerbating legal uncertainty and making it difficult for tax authorities to effectively levy taxes on cryptocurrency activities. Furthermore, the 2015 Civil Code of Vietnam does not include digital assets within its definition of property, which also presents significant obstacles for the tax administration of cryptocurrencies.

Compared to Vietnam's clear stock trading tax system, activities in the crypto sector have been exempt from tax obligations for a long time. This situation has made Vietnam a de facto "tax haven" in the crypto field, attracting a large number of crypto investors but also leading to a huge gap in government tax revenue.

3.2 New Regulations Outline Legal Framework for Taxing Cryptocurrencies

The "Digital Technology Industry Law" will officially take effect on January 1, 2026, marking a key step for Vietnam in terms of cryptocurrency tax policy. Although it does not directly enact a cryptocurrency tax law, it lays the legal foundation for future taxation. This new law explicitly defines "crypto assets" and "virtual assets" for the first time at a legal level, despite excluding securities, stablecoins, and central bank digital currencies (CBDCs). This milestone definition changes the previously ambiguous legal status of cryptocurrencies in Vietnam, making it likely to be regarded as legitimate property.

Against this backdrop, the Ministry of Finance is finalizing a draft resolution on a pilot program for the issuance and trading of cryptocurrencies. The pilot will assess the possibility of applying Value Added Tax (VAT), Corporate Income Tax (CIT), and Personal Income Tax (PIT) to cryptocurrency asset transactions. The pilot program will be conducted on a small scale and will be closely monitored by national regulatory agencies to study how to determine the income from cryptocurrency assets, thereby establishing transparent regulations to avoid budget losses and protect investors' rights.

There are currently various discussions regarding the proposed tax rates. One suggestion is to impose a 0.1% transaction tax on cryptocurrency transactions, similar to stock trading, which is believed to generate considerable revenue without overly suppressing market vitality. If cryptocurrencies are classified as investment assets, trading profits could be subject to capital gains tax like stocks or real estate. Businesses engaged in cryptocurrency trading may be required to pay the standard 20% corporate income tax. Additionally, there are suggestions to impose a personal income tax of 5–10% on profits from non-fungible tokens, and a withdrawal fee of 1–5% on profits for foreign investors, while considering a 10% corporate income tax incentive for pilot exchanges (for the first five years), as well as exempting digital asset trades from value-added tax to promote liquidity.

4 Outlook on Vietnam's Cryptocurrency Policy

The attitude of the Vietnamese authorities towards crypto assets has undergone a significant transformation from early caution and restrictions to the current proactive exploration and regulation. This shift reflects a pragmatic balance between controlling financial risks (such as money laundering and fraud) and seizing opportunities for the development of the digital economy. The authorities may have realized that simply banning or ignoring crypto assets would lead to a brain drain and capital outflow, missing the opportunity to secure a place in the global wave of the digital economy. In fact, the Vietnamese authorities have included blockchain technology, digital assets, and cryptocurrencies in the national strategic technology list, alongside cloud computing and artificial intelligence. This indirectly indicates that Vietnam sees digital assets as a key element in driving the country's digital transformation and economic growth.

Based on current development trends and the government's clear signals, there is reason to believe that Vietnam's future cryptocurrency asset policy will continue to exhibit characteristics of "inclusive prudence." Specifically, the following predictions can be made about the direction of Vietnam's future cryptocurrency asset policy:

Firstly, more regulatory details will be introduced and implemented. With the enforcement of the "Digital Technology Industry Law", more supporting regulations and guidelines will be issued to clarify the licensing requirements, operational standards, consumer protection measures, etc., for cryptocurrency asset service providers. The regulatory sandbox will continue to play a role, providing a controlled testing environment for new business models and technologies to accumulate experience and improve the long-term regulatory framework, ensuring that innovation occurs under controllable risks.

Secondly, the tax framework will be gradually improved and implemented. It is expected that after the "Digital Technology Industry Law" takes effect, the Ministry of Finance will accelerate the introduction of specific tax details, clarifying the taxation methods, tax rates, and collection processes for various types of crypto activities. The successful experience of the e-commerce platform tax system is likely to be introduced to crypto trading platforms to improve tax efficiency and compliance. Vietnam may also develop differentiated tax policies for different types of crypto activities and consider a combination of capital gains tax and turnover tax to achieve fairness and effectiveness in taxation.

Thirdly, digital assets and the traditional financial system will gradually integrate. The Vietnamese government will continue to promote the combination of digital assets with the traditional financial system, such as exploring the development of crypto banks, national crypto exchanges, and stablecoins to build a more modern financial infrastructure.

In summary, Vietnam may become a model of "compliance innovation" in the Southeast Asian crypto economy, competing with Thailand and Malaysia for the Southeast Asian crypto market. Vietnam has a large base of crypto users and a relatively clear strategy for the development of its digital economy. Recent legislation, such as the newly passed "Digital Technology Industry Law" and the ongoing promotion of tax pilot programs and sandbox mechanisms, indicate that it is transitioning from a "gray area" to "clear regulations." This transformation will allow it to stand out in the Southeast Asian region as a market that embraces innovation while ensuring compliance. Vietnam's experience may provide a viable model for other emerging markets and developing countries on how to gradually establish a sound regulatory and tax system for crypto assets without stifling innovation, thereby turning the potential of the crypto market into a driver of national economic growth.