This article, written by Tiger Research , provides an in-depth analysis of Vietnam's new cryptocurrency exchange regulations: with a minimum registered capital of $380 million, international giants like Binance and Bybit are locked in a fierce competition with local institutions for limited licenses.

Summary of key points

• Vietnam’s new regulatory framework sets extremely high entry barriers, and only large banks, securities firms or global exchanges with strong partners can hope to meet the standards.
• Although the seven local companies have made early arrangements, most of them have weak capital strength and insufficient institutional qualifications, making it difficult to meet regulatory requirements.
• Binance and Bybit have been received by senior Vietnamese government officials, indicating that foreign exchanges will share the market with a few local licensed institutions.

1. A new era of regulation: Vietnam’s digital asset market moves towards standardization

In 2025, Vietnam's digital asset market underwent a decisive transformation. After years of regulatory ambiguity, the government launched three major policy frameworks, marking the country's official transition from a laissez-faire "gray area" to a new stage of comprehensive regulation and controllable taxation.

The primary cornerstone is the Digital Technology Industry Law , passed by the National Assembly in June 2025 and scheduled to come into force on January 1, 2026. This law, for the first time, legally clarifies the independent status of digital assets, distinguishing them from securities and legal tender instruments. This provides a legal basis for subsequent taxation, anti-money laundering supervision, and law enforcement authority. Specific details will be further clarified through implementing regulations.

The second key measure is the Regulatory Sandbox Decree , which came into effect on July 1, 2025. Led by the State Bank of Vietnam, the sandbox mechanism provides a testing environment for financial innovation. Although not specifically designed for cryptocurrencies, it is expected to form a regulatory linkage with the exchange licensing system through core requirements such as anti-money laundering, customer identity verification, and settlement. The most immediately influential is Resolution No. 05/2025/NQ-CP , issued on September 9, 2025, which officially launched a five-year pilot program for the issuance and trading of virtual assets. This became the first practical framework for exchanges to legally operate in Vietnam. The key restriction is that during the pilot phase, only Vietnamese local companies can apply for operator licenses, and foreign exchanges must participate indirectly through joint ventures or by providing technology, compliance systems, and liquidity support.

This series of combined measures demonstrates the government's intention to gradually integrate digital asset activities into the domestic system under strict supervision. The policy clearly favors local control, alignment with international anti-money laundering standards, and is deeply aligned with the strategic goal of building Da Nang into a regional financial hub.

For institutions, the key point is that Vietnam has left its regulatory vacuum, a positive sign. However, high licensing requirements and restrictions on foreign investment suggest that openness remains limited. The next 12-18 months will tell whether Vietnam can develop into a structural market or remain a policy testing ground.

2. High threshold for licensed operations

Resolution No. 05/2025/NQ-CP, issued on September 9, 2025, sets strict entry conditions for Vietnam's five-year cryptocurrency pilot: only Vietnamese companies registered in accordance with the Enterprise Law are eligible to apply as operators.

Licensed institutions must maintain a minimum authorized capital of VND10 trillion (approximately US$380 million), all paid in VND. At least 65% of this capital must come from institutional shareholders, and more than 35% of this capital must be jointly invested by at least two of the following types of organizations: commercial banks, securities firms, fund management companies, insurance companies, or technology companies. Institutional shareholders must also have two consecutive years of profitability and an unqualified audited financial report.

Foreign ownership is strictly limited to 49% of authorized capital, ensuring operational control remains local. Furthermore, licensed institutions must meet stringent human resources and infrastructure requirements: the CEO must possess at least two years of financial industry experience, the technical director must possess five years of relevant IT experience, and the organization must employ at least ten employees with cybersecurity certifications and ten with securities qualifications. Technical systems must meet the highest national information security level 4 certification, the highest standard in the financial industry.

While this framework demonstrates the government's commitment to market regulation, its requirements pose challenges even for established financial institutions. If the scope is expanded to include wallet services, GameFi projects, or mid-sized exchanges, the vast majority of crypto-native businesses will struggle to meet the standards.

KyberSwap restricts access to Vietnamese users. Source: KyberSwap

Notably, Vietnamese projects like KyberSwap and Coin 98 have voluntarily suspended domestic operations. In practice, a hybrid model is likely to emerge: banks, securities firms, insurance companies, and tech giants will form the core of licensed entities, while Web 3 projects will participate as technology and service providers. As these factors grow and decline, market dominance will shift toward licensed institutions, potentially marginalizing startups and crypto-native projects.

Business scope is also strictly restricted: only asset-backed token issuance and spot trading are permitted, and settlement must be in Vietnamese dong. Cryptocurrency payment functions remain prohibited, and derivatives and leveraged trading are not permitted. Compared to pioneers such as the United States, Singapore, and Hong Kong, Vietnam's permitted business scope is significantly narrower.

3. The confrontation between local and international forces

3.1 Layout of local participants

Many Vietnamese companies have already registered and established "digital asset exchange" entities to seize the opportunity after the new policy is implemented. However, the current capital scale and equity structure of these institutions are still far from the mandatory requirements of Resolution 05/2025.

For institutional investors, three observations are worth noting. First, the capital gap is crucial. All current participants have capitalization levels ranging from VND 2 billion to VND 1.47 trillion, well below the legal minimum requirement of VND 10 trillion. Without significant capital injections from banks, securities firms, or insurance companies, most of these entities will not qualify for licenses.

Second, institutional anchoring will determine survival. The resolution requires at least 65% institutional ownership, including a 35% stake by at least two banks, securities firms, insurance companies, or technology companies. This provision clearly favors participants already connected to major financial institutions such as SSI, VIX, Techcom, HD, and MB, while placing fintech-led vehicles like DNEX or CAEX at a disadvantage unless they can attract stronger partners.

Finally, market expectations suggest that licensing will be limited. Rumors suggest that no more than five operators will be approved in the initial phase. With at least seven competitors already positioning themselves, some are bound to be excluded. For global exchanges evaluating the Vietnamese market, this heightens the importance of aligning with the most credible domestic partners as early as possible.

3.2 Strategic Interactions between Global Players and Governments

Bybit CEO Zhou Ben meets with Vietnamese Deputy Prime Minister Nguyen Hoa Binh. Source: Bybit

Global exchanges are actively building bridges of communication with the Vietnamese government. On September 24, 2025, during an official visit to the UAE, Deputy Prime Minister Nguyen Hoa Binh met with Binance CEO Richard Teng. The Deputy Prime Minister personally invited Binance to establish its regional headquarters in Da Nang and participate in the development of a licensed digital asset exchange within the Vietnam International Financial Center. Teng, who previously led Abu Dhabi Global Markets, was also invited to serve as a senior advisor to the Vietnam Financial Center. This move, announced through official government channels, sends a clear policy signal.

Binance CEO Richard Teng meets with Vietnamese leaders in Danang. Source: Binance

During the same period, the Da Nang People's Committee and Binance signed a memorandum of understanding, establishing strategic cooperation in the blockchain and digital asset sectors. This signifies Binance's high-level endorsement and a framework for cooperation with the local government.

Bybit is also aggressively pursuing its strategy. On September 17, 2025, it signed a tripartite memorandum of understanding with the Da Nang People's Committee, the Abu Dhabi Blockchain Center, and Verichains. The cooperation covers liquidity provision, infrastructure security, and ecosystem connectivity, precisely aligning with Vietnam's regulatory objectives. While not reaching the level of high-level meetings like Binance, it lays a practical foundation for its participation in the development of an international financial center.

The current landscape suggests that Binance and Bybit have already seized the lead in the global exchange race in Vietnam. If, as rumored, only five licenses are issued, with two reserved for international exchanges, only three spots remain for local companies. Faced with at least seven poised competitors, local institutions must rapidly demonstrate their strength and institutional background to secure the remaining spots.

This move also raises a series of questions: What will become of global exchanges like BingX and MEXC, which already dominate Vietnam's retail market? These exchanges, which serve Vietnamese users through offshore platforms, risk being marginalized in the licensed market if they fail to engage with the government promptly. Unless they quickly form alliances with approved local entities or secure special invitations, their operations will continue to operate outside of regulation, potentially exposing them to regulatory risks once the licensed market matures.

4. Strategic Breakthrough: The "CEX Tiger" Virtual Case Study's Path to Entry

What options do projects seeking to enter Vietnam have under the new regime? Consider the hypothetical case of "CEX Tiger," a global exchange planning to expand into Vietnam, and which strategies would be most viable.

The first and most important decision is choosing a partner. Foreign exchanges cannot obtain a license directly and must align themselves with strong domestic institutions. Determining which Vietnamese banks, securities firms, or insurance companies are most likely to receive a limited license is crucial. The choice of partner will determine market access, compliance posture, and long-term scalability.

Once a partner is secured, the next step is to define the operating model. A hybrid structure is necessary: the Vietnamese partner holds licensing and regulatory responsibilities, while CEX Tiger contributes technology, liquidity, and operational expertise. The joint venture becomes the formal entity, with the domestic institution acting as the legal and regulatory front end and the foreign exchange operating the underlying services.

Business expectations must also be calibrated. The framework restricts activity to spot trading, Vietnamese Dong settlement, and limited investor participation. This is not a market designed for immediate trading volume or derivatives-driven revenue. Instead, the strategic goal should be to secure an early presence, establish regulatory goodwill, and build legitimacy ahead of potential future liberalization.

However, competition will be fierce. If two licenses are allocated to Binance and Bybit, only three domestic institutions will remain. For latecomers, the real question is not whether Vietnam is attractive—the market's growth and user base make that clear—but whether a credible domestic partner can be secured and whether that partner is willing to cooperate. Missing out on the first round of licenses could delay entry until the framework is expanded.

Exchanges like CEX Tiger should view Vietnam as a long-term strategic fulcrum rather than a source of short-term profits. The key to success lies in selecting the best local partners, maintaining a minority equity position, and proactively cultivating Asia's most promising crypto market.

From the user side, the challenges are even more complex. Vietnamese users are accustomed to global trading platforms. Even if licensed, new entrants will still face challenges in security standards, asset categories, and platform stability. While a license provides compliance, it doesn't automatically translate into user trust and market share.

CEX Tigers face a final strategic decision: join forces with local partners to compete for licenses, or remain outside the regulatory periphery, retain existing users, and closely monitor policy evolution. This strategic game for the Vietnamese market has just begun.