Vietnam’s ambitious five-year pilot program for digital asset trading, officially launched on September 9, 2025, under Resolution No. 05/2025/NQ-CP, has yet to receive a single application from prospective participants. The Ministry of Finance confirmed on October 6, 2025, that while several companies are preparing submissions and engaging in preliminary discussions, the high entry barriers—including a minimum capital requirement of 10 trillion Vietnamese dong (approximately $379 million) and restrictions on product offerings like stablecoins and tokenized securities—have deterred formal interest. For crypto industry professionals, regulatory experts, and investors searching Vietnam crypto pilot no applications, Resolution 05/2025 crypto barriers, or Vietnam digital asset licensing 2025, this stall highlights the challenges of regulating an emerging market where Vietnam ranks fourth globally in crypto adoption (per Chainalysis 2025 Index), with 17 million users and $100 billion in annual trading volume mostly on offshore platforms. Deputy Minister Nguyen Duc Chi expressed hope for a pre-2026 launch, contingent on companies meeting the conditions, but analysts warn the pilot risks becoming a “stuck experiment” if liquidity and innovation remain offshore.
The program, capped at five licenses, aims to shift activity to onshore, regulated channels, but the steep requirements have left local firms scrambling and global players like Binance and Bybit in talks without commitments.
High Barriers: $379 Million Capital and Product Restrictions
Resolution 05/2025 sets rigorous entry criteria to ensure stability and compliance, but they’ve proven prohibitive for most applicants.
- Capital Requirement: Minimum 10 trillion VND ($379 million), far exceeding Singapore’s $1-5 million non-bank thresholds.
- Product Limits: Bans on fiat-backed stablecoins (e.g., USDT, USDC) and tokenized securities, restricting offerings to spot trading of select assets.
- Ownership and Staffing: Strict foreign ownership caps and mandatory local expertise.
Several Vietnamese firms have rebranded as “digital asset exchanges” in anticipation, but their capitalization falls short. Global players like Binance and Bybit are discussing systems with officials, but no formal proposals have landed.
| Requirement | Detail | Comparison (Singapore) |
|---|---|---|
| Minimum Capital | $379 Million | $1-5 Million |
| Stablecoins Allowed | No | Yes (Regulated) |
| License Cap | 5 Firms | Unlimited (Tiered) |
| Ownership | Strict Caps | Flexible |
Vietnam’s Crypto Landscape: High Adoption, Low Regulation
Vietnam’s crypto enthusiasm—fourth in Chainalysis’ 2025 Global Adoption Index—contrasts with regulatory caution. APAC transaction volume hit $2.36 trillion in 2025, with Vietnam contributing significantly via offshore exchanges.
- User Base: 17 million traders, mostly on Binance, Bybit, and Hong Kong/Singapore platforms.
- Market Size: $100 billion annual volume; stablecoins dominate for remittances.
- Policy Evolution: Builds on the June 2025 Digital Technology Industry Law, recognizing digital assets as property.
Deputy Minister Chi: “We hope to launch before 2026, depending on enterprises meeting conditions.”
Implications: Stalled Pilot Risks Offshore Migration
The lack of applications could:
- Delay Onshore Shift: Keep liquidity offshore, limiting tax revenue and AML oversight.
- Favor Global Giants: Binance/Bybit may dominate if locals can’t compete.
- Boost Neighbors: Singapore/Hong Kong attract firms with lighter rules.
Analysts like those at Tiger Research note: “High barriers may turn the pilot into a stuck experiment.”
Conclusion: Vietnam’s Crypto Pilot in Limbo
Vietnam’s crypto pilot with no applications due to $379 million barriers risks stalling innovation, despite top adoption rankings. As firms prepare, a 2026 launch hangs in balance. For Southeast Asia’s crypto hub, it’s a regulatory test—will easing rules follow? The licenses linger. Tradingview
