The legal framework for digital assets in Vietnam is entering a distinct phase of formation with two key documents: Resolution 05/2025/NQ-CP of the Government and Resolution 222/2025/QH15 of the National Assembly. This article helps you quickly grasp the scope, mechanism and practical significance of each resolution, along with a checklist of actions for investors and businesses to "play by the rules".
Resolution 05/2025/NQ-CP: Pilot licensing of digital asset trading floors
Area
- Pilot up to 05 digital asset trading floors nationwide, period 2025-2028.
Management agency
- Ministry of Finance, State Bank of Vietnam, Ministry of Information and Communications.
Core conditions for the floor
- Capital capacity and risk management meet requirements.
- Technology infrastructure meets level 4 information security standards.
- Full KYC/AML compliance and regular reporting.
Practical significance
- Only exchanges licensed within the pilot framework are considered legal.
- Individuals and businesses can rest assured when trading on these exchanges.
Suggested Action
- Investors: only trade on exchanges included in the announced pilot list.
- Enterprises wishing to operate a floor: prepare pilot application documents according to Resolution 05.
Resolution 222/2025/QH15: International Finance Center and experimental sandbox
Area
- Establishment of International Finance Center (IFC) in Ho Chi Minh City and Da Nang.
Participation mechanism
- Allow financial technology and digital asset organizations to become members of the TTTCQT.
Sandbox (supervised testing environment)
- New models such as DeFi, GameFi, RWA and other digital asset products can be tested within the scope of supervision.
Practical significance
- Businesses are legally allowed to test products in a risk-controlled environment.
- Investors participating in products in the International Financial Market are better protected by the legal framework.
Suggested Action
- Fintech, blockchain, and exchange businesses: consider applying to the International Financial Center for pilot testing and taking advantage of appropriate incentives.
- Investors: prioritize participating in products in the International Financial Market to reduce legal risks.
Quick Understanding
- Resolution 05: Limited official licensing for some digital asset exchange operate legally nationwide.
- Resolution 222: establishment "special zone" (TTTCQT) where businesses and investors legal testing digital asset products in a supervised sandbox.
Compliance Checklist for Individuals and Legal Entities
- Only trade on floors licensed under Resolution 05 or in the international financial market space under Resolution 222.
- Businesses that want to operate the floor:
- Submit application for pilot according to Resolution 05; or
- Please recognize TTTCQT members according to Resolution 222 to operate in the sandbox.
- Submit application for pilot according to Resolution 05; or
- Do not arbitrarily raise capital or issue tokens without legal recognition.
- Establish and comply with KYC/AML procedures, data storage and periodic reporting as required by regulatory agencies.
Conclude
- Resolution 05 = national license for digital asset exchange.
- Resolution 222 = sandbox space in TTTCQT for legal testing of digital asset products.
Individuals and legal entities only need to follow these two resolutions to transact and operate legally, minimize legal risks and promote a transparent and safe digital asset market.
