Pilot Regulatory Framework for the Crypto Asset Market

Following the statutory recognition of crypto assets under the Digital Technology Law, the Government enacted Resolution 05/2025/NQ-CP on 9 September 2025, establishing a controlled five-year pilot programme (2025–2030) for the issuance, trading, and supervision of crypto assets in Vietnam (the “Crypto Pilot Programme”).

The Crypto Pilot Programme adopts a selective approach to market participation, with specific provisions regulating the activities of stakeholders as follows.

(i) Crypto Asset Issuers:

Under the Crypto Pilot Programme, only Vietnamese-incorporated companies may offer or issue crypto assets.⁵ The eligibility requirement does not appear to exclude Vietnamese…