Vietnam Says Five Crypto Exchange Applicants Cleared Initial Review, but No License Issued Yet

High capital and security thresholds for applicants

Under Resolution No. 05/2025/NQ-CP, each exchange applicant must show at least 10 trillion Vietnamese dong in contributed charter capital, roughly $383 million. That amount must be contributed in Vietnamese dong, and at least 65% must come from institutional shareholders.

The rules also require that more than 35% of the charter capital be provided by at least two qualifying organizations, which can include commercial banks, securities firms, fund managers, insurers or technology companies. Vietnam has not said whether the five applicants that cleared the first review have already secured the full capital required.

Applicants must also obtain an appraisal showing their technology meets Level 4 information-system security standards. The Ministry of Public Security is responsible for the required security assessment before an exchange can start operations. Additional licensing conditions cover management qualifications, custody arrangements, transaction monitoring, internal controls, conflict management, customer complaints, anti-money laundering systems and investor identity checks. The 10 trillion dong figure is charter capital, not a separate fee paid to the state.

New penalties begin Sept. 1

Decree No. 284/2026/ND-CP will take effect on Sept. 1 and remain in force while Resolution 05 governs the pilot market. It sets penalties for unlicensed crypto services, improper issuance, weak customer verification and failures tied to anti-money laundering compliance.

Organizations that provide crypto services or advertise an exchange without a license can be fined between 180 million and 200 million dong. Authorities may also require the removal of websites, software and trading systems involved in violations. Licensed providers can be penalized for failing to segregate customer assets, monitor transactions or protect account information.

The decree generally lists fines for organizations. Individuals who commit the same violations usually face half those amounts. The maximum penalty under the decree is 200 million dong for an organization and 100 million dong for an individual.

Domestic investors are not yet on the clock

The new decree also includes a fine of 30 million to 50 million dong for domestic investors trading through a provider not licensed by the Ministry of Finance. But that rule does not begin on Sept. 1, because the countdown starts only six months after the first crypto asset service provider receives approval.

Since no provider has been licensed yet, domestic investors will not be fined from Sept. 1 solely for using overseas or otherwise unlicensed platforms. That distinction matters because other parts of Decree 284 can still be enforced immediately, including penalties for operating or promoting unauthorized platforms, improper token issuance and certain failures involving customer data or anti-money laundering controls.

What comes next in the pilot

Vietnam introduced the pilot through Resolution 05 on Sept. 9, 2025. In its initial form, the framework allows only locally issued crypto assets to be offered to foreign investors. Eligible tokens must be backed by real-world assets and cannot represent securities or fiat currencies under the pilot.

Only a limited number of exchanges were expected to receive licenses. The report that five companies passed the first assessment shows preliminary progress, but it does not establish that those firms can operate or that they will all win final approval.

The next confirmed milestone is the Ministry of Finance issuing the first license. Once that happens, a six-month transition period will begin before domestic investors must conduct covered crypto trading through licensed Vietnamese providers. No deadline for the first license has been announced, so official notices from the Ministry of Finance and the State Securities Commission remain the key reference point.