Directive 05/CT-TTg: Vietnam's Crypto Framework Development and Its Strict New Rules
Crypto Capital Requirement Calculator
Vietnam's Requirement
$379 million USD
10 trillion VND
How This Compares to Other Countries
On September 9, 2025, Vietnamâs government dropped a regulatory bomb: Resolution No. 05/2025/NQ-CP. It didnât just tweak the rules-it rewrote the entire playbook for cryptocurrency in the country. No more gray areas. No more unregulated exchanges. If you want to operate a crypto platform in Vietnam now, you need at least 10 trillion VND-roughly $379 million-in capital. And thatâs just the beginning.
What Exactly Is Directive 05/CT-TTg?
Directive 05/CT-TTg isnât a standalone law. Itâs the operational arm of Resolution No. 05/2025/NQ-CP, signed by Deputy Prime Minister Ho Duc Phoc. This isnât a suggestion. Itâs a mandate. The government is launching a five-year pilot program (2025-2030) to bring cryptocurrency under formal state control. Before this, Vietnam had one of the highest crypto adoption rates in the world-21 million users, according to Chainalysis. But nearly all of them were using platforms with no legal backing. Now, those platforms must either meet impossible capital requirements or shut down.
The Ministry of Finance is now the sole gatekeeper. No other agency can issue licenses. And the rules arenât just strict-theyâre designed to limit participation. Foreign ownership? Capped at 49%. Transactions? Must be in Vietnamese dong (VND) only. No USD, no EUR, no stablecoins backed by dollars or euros. Thatâs a huge deal. Stablecoins made up over 60% of all crypto transactions in Vietnam before this law. Now, theyâre banned.
The $379 Million Barrier
Letâs be clear: $379 million isnât a high bar. Itâs a wall.
Compare it to Thailandâs requirement: 500 million THB ($13.7 million). Or Singaporeâs flexible model, where capital depends on business scope. Vietnamâs requirement is 27 times higher than Thailandâs. Thatâs not about safety-itâs about control. Only a handful of state-linked or ultra-rich private groups can even begin to meet this. Smaller exchanges, the ones that served local users with low fees and fast withdrawals, are done. One Reddit user, HanoiTrader88, posted that his platform had $190,000 in capital. Heâs out. No appeal. No grace beyond the six-month transition window.
And raising that kind of money isnât easy. The resolution requires at least 65% of the capital-6.5 trillion VND-to come from institutional investors. That means banks, state-owned enterprises, or big conglomerates. No individual investors. No crowdfunding. No venture capital from startups. The system is built to favor existing power structures, not innovation.
Why VND-Only Transactions?
One of the most surprising moves is the ban on foreign currency settlements. Every trade, every deposit, every withdrawal must be in Vietnamese dong. The State Bank of Vietnam says this prevents capital flight-a real concern. In 2025, an estimated $10.2 billion flowed out of Vietnam through unregulated crypto channels. Thatâs a massive drain on the national currency.
But the side effect? It kills international liquidity. Traders who want to move between Bitcoin, Ethereum, or even stablecoins canât easily convert to USD or EUR. Theyâre locked into VND. That means lower trading volumes, wider spreads, and less incentive for global traders to use Vietnamese platforms. Indonesia tried something similar in 2023. The result? Most users migrated to offshore exchanges. Vietnam could see the same.
The Stablecoin Ban: A Strategic Mistake?
Hereâs where the framework stumbles. The resolution explicitly bans crypto assets backed by fiat currencies or securities. That means no USDT, no USDC, no DAI. These stablecoins are the backbone of global crypto trading. Theyâre how people hedge volatility, move money quickly, and access DeFi. In Vietnam, they made up 63.8% of all crypto transactions in 2025.
By banning them, Vietnam is cutting off its own nose to spite its face. Why force users into a system where every trade requires converting to VND, then back to crypto? It adds friction, cost, and delay. It also makes Vietnamâs exchanges irrelevant to institutional players who rely on stablecoins for arbitrage and liquidity.
As Cointelegraph analyst Amin Haqshanas noted, this move âmay limit its appeal to institutional investors.â Thatâs an understatement. It likely eliminates it.
Who Wins? Who Loses?
The winners? The state. The Ministry of Finance gains full oversight. The State Bank of Vietnam gets real-time transaction data through its new NDAChain blockchain system. Large, well-connected investors who can raise $379 million will get licenses-and likely a monopoly on the market.
The losers? Everyone else.
- Small exchanges: 99% of the 21 million users wonât have legal platforms to use.
- Traders: Theyâll face higher fees, slower withdrawals, and fewer assets.
- Innovators: Startups building DeFi tools or NFT platforms in Vietnam will lose their user base.
- Investors: Those who lost money in 2022 when 15 unregulated platforms collapsed now have a regulated system-but one so restrictive it may not serve them better.
On Reddit, SaigonVC wrote: âFinally some regulation!â But thatâs the voice of a wealthy investor who can afford to play by these rules. For the average Vietnamese crypto user, itâs a loss. A 2025 survey by CoinGeek found 79.6% of users think the capital requirement is too high. 41.2% said theyâd move to offshore platforms if local options become too restricted.
Compliance Costs and Implementation Chaos
Even if you have the money, getting compliant is expensive. Legal firm Duane Morris Vietnam estimates it will cost between $1.9 million and $7.6 million per exchange to upgrade systems, integrate with NDAChain, implement KYC/AML protocols, and restructure ownership. Thatâs on top of the $379 million capital requirement.
And the regulators arenât ready either. The Ministry of Finance created a Crypto Asset Regulatory Department (CARD) with 45 staff. But Vietnamâs Academy of Social Sciences says they need at least 120 to monitor 21 million users. Thatâs a 1:467,000 ratio. Compare that to the U.S. SECâs ratio of 1:20,000 for broker-dealers. Vietnamâs system is set up to fail under its own weight.
The six-month grace period after the first license is issued is another wildcard. When will that first license come? The Ministry says applications open in 30 days, with first licenses in 90-120 days. That means users could be left in limbo for months. And when the grace period ends? Those still on unlicensed platforms could lose access overnight.
What Happens Next?
Industry analysts predict only 3 to 5 exchanges will qualify for licenses in the first year. Theyâll serve maybe 5 million users-down from 21 million. The rest? Theyâll go offshore. Or theyâll use peer-to-peer (P2P) platforms, which are harder to regulate. Vietnamâs government might control the exchanges-but it canât control the people.
Tax rules are coming. By November 15, 2025, capital gains will be taxed at 0.1% for trades under 100 million VND and 0.3% for larger ones. Thatâs low, but itâs another layer of control. The government wants to track every transaction, tax every gain, and own the narrative.
The five-year pilot includes review points at 12, 24, and 36 months. That means the rules could change. But donât expect them to loosen. The governmentâs goal isnât to foster innovation-itâs to capture control. Vietnam wants to be part of Southeast Asiaâs digital economy, but on its own terms. And those terms are strict, centralized, and exclusionary.
How This Compares to the Region
Thailand licensed 12 exchanges by August 2025. Singapore allows foreign-owned platforms with flexible capital rules. Indonesia bans retail trading but lets institutions trade futures. China? Total ban. Vietnam sits in the middle-but leans hard toward Chinaâs control model.
Itâs not about being the most open. Itâs about being the most secure-for the state. The trade-off? Innovation dies. User choice shrinks. And the market, once vibrant and grassroots, becomes a state-sanctioned oligopoly.
Final Reality Check
This isnât a crypto-friendly policy. Itâs a state control policy disguised as regulation. The government isnât trying to protect users-itâs trying to prevent capital flight, eliminate competition, and take full ownership of the digital asset flow.
For users, the choice is simple: comply with a system designed to exclude you, or find another way. Many will choose the latter. And thatâs the irony. The more Vietnam tries to control crypto, the more it pushes it underground.
The $379 million rule wonât stop crypto in Vietnam. Itâll just make it harder, more expensive, and less accessible. The real winners wonât be traders or startups. Theyâll be the few entities that can afford to play by the new rules-and the government that now owns the game.
Is cryptocurrency legal in Vietnam now?
Yes-but only if youâre a licensed exchange that meets the governmentâs strict requirements. Individuals can still hold and trade crypto, but only through platforms approved by the Ministry of Finance. All unlicensed exchanges must shut down by the end of the six-month grace period after the first license is issued.
Can I still use USDT or USDC in Vietnam?
No. The new framework explicitly bans any crypto asset backed by fiat currencies like the U.S. dollar or euro. That means USDT, USDC, and similar stablecoins are prohibited on licensed Vietnamese exchanges. Users who want to trade them must use offshore platforms, which carry higher risks and no legal protection.
Do I need to pay taxes on crypto in Vietnam?
Yes. Starting November 15, 2025, capital gains from crypto transactions will be taxed. Transactions under 100 million VND (about $3,900) are taxed at 0.1%. Larger trades are taxed at 0.3%. This applies to all users, whether trading on licensed or unlicensed platforms, though only licensed platforms will report to tax authorities.
Can foreigners own a crypto exchange in Vietnam?
Foreigners can own up to 49% of a licensed cryptocurrency exchange in Vietnam. The remaining 51% must be held by Vietnamese individuals or entities. This rule is designed to ensure local control over financial infrastructure and prevent foreign dominance of the market.
What happens to small crypto exchanges in Vietnam?
They will be forced to shut down unless they can raise at least 10 trillion VND ($379 million) in capital, with 65% coming from institutional investors. Most small exchanges have less than $1 million in capital. Without access to that level of funding, they have no legal path to continue operating.
Will Vietnamâs crypto market shrink because of these rules?
Yes, significantly. Before the rules, 21 million Vietnamese users traded crypto. Analysts predict only 3-5 licensed exchanges will launch in the first year, serving at most 5 million users. The rest will likely move to offshore platforms, use P2P networks, or stop trading altogether. Transaction volume could drop by 75% or more in the short term.
How does this compare to other countries in Southeast Asia?
Vietnamâs rules are the strictest in the region. Thailandâs capital requirement is about $13.7 million-27 times lower. Singapore allows foreign ownership and has flexible capital tiers. Indonesia bans retail trading but allows institutional futures. China bans everything. Vietnam is in between-but leans toward Chinaâs control model, with the highest capital barrier and the most restrictive asset rules.
Looking ahead, Vietnamâs crypto future wonât be defined by innovation or user freedom. Itâll be defined by control, capital, and compliance. The government has chosen its path. Now, the market must adapt-or disappear.
andrew seeby
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