In the early stages of a market, where regulations are not yet fully established, the advantage usually lies with those who move quickly. But once the rules of the game are defined, market logic changes completely. The advantage no longer belongs to the fastest runner, but to those who can build the infrastructure, control risks, and operate on a large scale. The Vietnamese digital asset market is entering this pivotal moment.
From the "gray area" to a component of the digital economy.
After years of operating within an unclear legal framework, digital assets are gradually being recognized as an integral part of the digital economy, rather than merely a speculative activity. As the legal framework begins to be researched and designed, the market enters a new cycle – the cycle of standardization and infrastructure.
According to international reports for the period 2023–2024, Vietnam consistently ranks among the top 5 countries with the highest adoption rates of digital assets worldwide. It is estimated that approximately 16–20 million Vietnamese people have held or currently hold digital assets in various forms.
The total value of transactions involving Vietnamese users fluctuates between $200 and $300 billion annually, depending on market cycles. This scale is equivalent to, or even surpasses, many traditional financial segments in the country.
However, over 70%'s trading volume still takes place on foreign platforms. This means that user data, transaction fees, profits, and operational expertise are flowing out of the domestic financial system.
Therefore, the question is no longer whether or not to recognize digital assets. The issue is how to keep cash flow, data, and technological capabilities within the Vietnamese economy.
When the rules of the game change, so do the advantages.
In the early stages of an unregulated market, fast-moving players can exploit legal loopholes and accept high risks to gain market share. However, as the legal framework develops, compliance costs increase, and operational standards are raised, shifting the advantage to entities capable of building systems.
The game is no longer about promises of short-term profits. This is the game of infrastructure.
Six layers of infrastructure determine market sustainability.
Blockchain is just the technical foundation. A legitimate digital asset market requires many layers of underlying infrastructure.
Firstly, there is the identification and compliance infrastructure, including eKYC, AML, and fund monitoring. Once the market is authenticated, compliance costs can account for 10–201 TP3T of total operating costs, but this is a prerequisite for connecting with the banking system and scaling up.
Secondly, there's the custody and security infrastructure, such as custody, MPC, internal authorization, audit trail, and risk insurance. As institutions become more deeply involved, the focus shifts from fast transactions to protecting assets safely and sustainably.
Thirdly, there is the on-ramp and off-ramp infrastructure, which allows conversion between fiat currency and digital assets. In standardized markets, this is often a stable and long-term revenue stream.
Fourth is data infrastructure and market surveillance, including real-time transaction tracking, manipulation detection, and standardized reporting to regulators. A market without supervision will soon destroy itself.
Fifth is the infrastructure for standardizing assets and products, which is especially important for real asset tokenization (RWA). Without legal and regulatory standardization, RWAs remain only at the experimental stage.
Sixth is the user experience and protection infrastructure, including risk warnings, investor classification, and information transparency. When the number of users reaches tens of millions, this is a vital condition for survival.
Infrastructure is not a fertile ground for hot money. Investors in digital asset infrastructure are typically long-term domestic technology companies, strategic investment funds willing to accept slower returns in exchange for platform ownership, or state-owned enterprises in national infrastructure sectors such as identity, data, and payments.
Opportunities for Vietnamese tech startups
The opportunity for startups lies not in creating more speculative assets, but in solving systemic problems.
Six areas with long-term potential include RegTech and identity, custody and security, on-ramp and payments, tokenization of real assets, market surveillance infrastructure, and financial education linked to user protection. These are all clear B2B areas with long-term demand and the potential to generate sustainable revenue.
Compared to centers like Singapore, South Korea, or the UAE, Vietnam has a distinct advantage: it is currently in the stage where the rules of the game are being designed, not yet rigidly defined. There is still room for innovation, and the cost of experimentation is lower.
However, this opportunity won't last forever. If standardization is slow, capital will continue to flow abroad, domestic startups will lose opportunities, and social management costs will increase.
Infrastructure determines who stays.
The digital asset market is no longer a distant future concept. It is directly impacting the cash flow, investment behavior, and financial security of tens of millions of Vietnamese people.
The question is no longer whether to participate, but how to participate. If we take a short-term approach, the market will continue to pay the price in terms of risk and loss of confidence. But if we take the path of infrastructure, standardization, and discipline, digital assets can become a new growth engine for Vietnam's digital economy.
In this pivotal stage, the fastest mover isn't guaranteed to win. Those who build the foundation are the ones who stay and have the chance to move forward.
Note: This article is for informational purposes only and is not an investment recommendation or offer to sell financial products. Readers should proactively research and understand Vietnam's current policies and legal framework through official documents.
Eric Vuong
Chairman of BOD
HVA Investment Joint Stock Company
