The Transformation Path of Vietnam's Crypto Assets Regulation and Tax System

For a long time, Vietnam's legal positioning on Crypto Assets has been unclear, and relevant tax policies have fallen into a gray area. However, this situation saw a significant turnaround on June 14, 2025. The National Assembly of Vietnam passed the "Digital Technology Industry Law," which for the first time incorporated Crypto Assets into the national legal framework and implemented classified regulation, officially granting them legal status, marking a milestone event in the country's Crypto Assets regulatory process.

The new law classifies digital assets into two categories: "virtual assets" and "Crypto Assets", granting the government the authority to formulate implementation rules, while also strengthening requirements for cybersecurity, anti-money laundering, and counter-terrorist financing. The law is set to take effect on January 1, 2026, aiming to improve the relevant legal system, align with international regulatory standards, and help Vietnam exit the FATF grey list as soon as possible.

This article will analyze the role of this legislative breakthrough in restructuring Vietnam's digital economy landscape, examining the latest dynamics and future trends of its tax system. By outlining the evolution of the Vietnamese government's policies from cautious observation to actively building a regulatory framework over the past few years, a comparative analysis will be conducted in conjunction with the practices of other representative countries in Southeast Asia and globally in the field of crypto assets taxation and regulation. In addition, the article will look ahead to Vietnam's strategies in balancing risk prevention and innovative development, predicting specific policies that may be introduced in the coming years, as well as the potential impact of these policies on Vietnam as an emerging digital economy.

1. Vietnam Clarifies the Legal Status of Crypto Assets

Before the promulgation of the "Digital Technology Industry Law", Vietnam's legal characterization of Crypto Assets had been in a vague and constantly evolving state. Initially, the Vietnamese government’s attitude towards Crypto Assets was mainly reflected in strict restrictions on their use as a payment method and risk warnings. For example, in a letter issued by the State Bank of Vietnam in July 2017, it was clearly stated that Crypto Assets such as Bitcoin and Litecoin are not recognized as legal tender or payment methods in Vietnam, and their issuance, supply, and use are explicitly prohibited, with violators facing potential sanctions. Subsequently, in April 2018, the Prime Minister issued a directive requiring relevant departments to strengthen the management of activities related to Crypto Assets to enhance control over related transactions and prevent potential harm.

Although the Ministry of Finance announced in an official letter in April 2016 that it would not prohibit Crypto Assets trading and defined them as "property" and "liquid goods," the lack of clear legislative support has left this directive in an ambiguous position in practice, making compliance and enforcement related to Crypto trading relatively complex. Furthermore, according to the definition of assets in Vietnam's 2015 Civil Code, digital assets such as Crypto Assets clearly do not fall into any of those categories, thus under current Vietnamese law, these assets themselves are not considered physical assets. This lack of classification has created significant legal gaps, directly impacting how these assets are handled and regulated within the legal framework.

However, this ambiguous situation underwent a fundamental change on June 14, 2025. The National Assembly of Vietnam passed the landmark "Digital Technology Industry Law," which will officially take effect on January 1, 2026. This law clearly defines "digital assets" for the first time in the Vietnamese legal system and further categorizes them into "Crypto Assets" and "virtual assets." This legislative breakthrough ended years of uncertainty regarding the legal status of Crypto Assets in Vietnam, officially recognizing Crypto Assets as legal property under civil law, thereby providing a solid legal foundation for individuals and organizations to establish and exercise property rights legally.

This strategic shift from "non-recognition" to "legalization" is not accidental, as the Vietnamese government has realized the immense potential of the crypto economy. Despite regulatory barriers, Vietnam has one of the highest cryptocurrency ownership rates globally, ranking fifth in the world, with about 20.95% of the population holding crypto assets, and an annual inflow of over $100 billion. At the same time, Vietnam also faces the need to respond to international anti-money laundering and counter-terrorist financing pressures, as it has been placed on the gray list by the Financial Action Task Force, requiring it to strengthen virtual asset management. Therefore, legalization is a necessary prerequisite for attracting investment, promoting the development of the digital economy, and effectively regulating this emerging industry. This indicates that the Vietnamese government has shifted from merely preventing risks to actively embracing the opportunities brought by the digital economy and is attempting to guide and regulate this emerging industry through the establishment of a sound legal framework, rather than simply suppressing it.

2. The Shift in Vietnam's Crypto Assets Regulatory Framework

The Vietnamese government's shift in its stance on the classification of Crypto Assets reflects a significant change in its regulatory system. In the past, Vietnam's Crypto Assets regulatory framework faced issues of inadequacy and passive responses, often employing a one-size-fits-all regulatory approach; however, with the rise of global Crypto Assets trends and changes in Vietnam's higher echelons, its regulatory system for Crypto Assets is currently being rapidly improved. Not only has an initial division of regulatory responsibilities been established, but discussions and implementations of various regulatory pilot projects are also being actively advanced, striving to effectively address challenges such as anti-money laundering and counter-terrorism financing while embracing new technologies.

2.1 Evolution of Regulatory Framework

Vietnam's Crypto Assets regulatory framework has undergone a significant evolution from non-existence to existence, from passive response to proactive guidance.

From 2016 to 2022, Vietnam's Crypto Assets regulatory system has evolved from non-existent to established, transitioning from a one-size-fits-all approach to a phase of exploration and research.

In April 2016, a letter from the Ministry of Finance announced that it would not prohibit Crypto Assets trading, but the classification was vague. Then in July 2017, the State Bank of Vietnam explicitly prohibited Bitcoin and other Crypto Assets as a means of payment, emphasizing their illegality. In April 2018, the Prime Minister issued a directive requiring strengthened management of activities related to Crypto Assets, while the State Bank also instructed financial institutions to enhance measures related to Crypto trading, reflecting the government's early cautious and risk prevention stance.

In May 2020, the Prime Minister instructed the national bank to launch a pilot project to explore the use of blockchain in Crypto Assets and required it to research and assess the pros and cons of Crypto Assets. In March 2022, the Vietnam Blockchain Association was established, becoming Vietnam's first legal entity focused on Crypto Assets, tasked with creating and nurturing the development framework for Crypto Assets. In the same year, Vietnam passed anti-money laundering legislation that came into effect in 2023, requiring institutions providing payment services to implement Know Your Customer measures, marking an important step in its international compliance efforts. In October 2022, the Prime Minister once again called for regulation of Crypto Assets, indicating the government's urgent need for normalization in this field.

After 2023, especially after the changes in Vietnam's leadership in 2024, Vietnam's regulatory attitude towards Crypto Assets is gradually softening.

In February 2024, the Prime Minister, through a decision, instructed the Ministry of Finance to draft a legal framework for virtual assets, clarifying the government's determination at the legislative level. In October of the same year, the Prime Minister signed a decision to promulgate the "National Strategy for the Development and Application of Blockchain Technology in Vietnam 2025," and looking towards 2030, aiming to make Vietnam a regional leader in blockchain innovation. The strategy clearly identifies blockchain as a core pillar of digital transformation and emphasizes the "Made in Vietnam" blockchain platform, indicating that the government has regarded blockchain and digital assets as important driving forces for the country's digital economy development.

In June 2025, the "Digital Technology Industry Law" was passed, which establishes a tolerant and prudent regulatory framework from multiple aspects, including clarifying the classification of digital assets, mandating the implementation of anti-money laundering and counter-terrorism financing measures, introducing a licensing system, and incentivizing emerging technologies such as artificial intelligence, semiconductors, and advanced computing, thereby promoting the broader development of the digital economy.

The maturity of the regulatory framework from "passive response" to "active guidance" is a key feature of Vietnam's policy evolution in the field of digital assets. In the early days, Vietnam's regulation of Crypto Assets primarily focused on "prohibiting the use as a means of payment" and "risk warnings," which represented a passive and precautionary stance. However, in the past two years, from the Prime Minister's directive for research, the establishment of the Blockchain Association, to the issuance of the "Law on Digital Technology Industry" and the National Blockchain Strategy, the regulatory focus has clearly shifted towards actively building a framework that incorporates Crypto Assets into the national digital economy development strategy. This marks Vietnam's entry into a more mature and pragmatic stage in digital asset regulation, where the goal is no longer merely to control risks, but to unleash innovative potential by establishing a clear and predictable legal environment, attracting domestic and foreign investment, and enhancing its position in the global digital economy.

Overview of the existing regulatory framework and division of labor in Vietnam 2.2

Vietnam's current crypto assets regulatory framework is primarily managed by various ministries, resulting in a "loose regulatory" pattern. Multiple key agencies, including the State Bank of Vietnam, the Ministry of Finance, the Ministry of Public Security, and the Vietnam Blockchain Association, collaborate to jointly build and improve the regulatory framework.

2.3 Regulatory Sandbox Pilot and Risk Compliance Construction under the New Normal

In order to explore innovative applications of digital assets under controllable risk, the Vietnamese government has actively introduced regulatory sandbox mechanisms and pilot projects.

The Vietnamese government is discussing the establishment of regional and international financial centers, one key aspect of which is the introduction of a controlled testing policy (sandbox) for financial technology, particularly aimed at business models involving Crypto Assets and cryptocurrency. This sandbox mechanism allows for small-scale testing of new financial technologies and business models in a controlled environment, thereby assessing their potential risks and benefits before full-scale rollout. For example, Da Nang has been authorized to pilot special mechanisms, including a project for international tourist payments using stablecoins, which is seen as an important attempt to explore the application of digital payments in the tourism industry. These pilot projects aim to accumulate practical experience to provide data and basis for a future more comprehensive regulatory framework.

In addition, Vietnam is actively exploring the research and development of the central bank digital currency------digital dong. The Prime Minister of Vietnam has repeatedly called for the national bank to study the pros and cons of digital currency and to initiate pilot encryption currency projects based on blockchain. Although the issuance of the digital dong is still in the assessment stage, its potential legal status and supplementary role to the traditional financial system are important components of Vietnam's digital economy development.

Of course, while promoting innovation in the regulatory framework, anti-money laundering and counter-terrorism financing compliance remain core concerns for the Vietnamese authorities, especially after being placed on the gray list by the Financial Action Task Force.

Vietnam is currently still on the "increased scrutiny list" (grey list) of the Financial Action Task Force, primarily due to its shortcomings in anti-money laundering practices related to Crypto Assets. Being placed on the grey list means that the country has strategic deficiencies in combating money laundering and terrorist financing, which may affect its international financial reputation and ability to attract foreign investment. To be removed from the grey list, Vietnam must develop policies for the management of virtual assets and strengthen relevant law enforcement.

The passage of the "Digital Technology Industry Law" is an important measure for Vietnam to respond to FATF pressure. The law explicitly requires all digital asset activities to strictly implement anti-money laundering and counter-terrorism financing measures to enhance security and transparency. This means that future crypto asset exchanges and related service providers must comply with global standards such as KYC and AML, and may be required to maintain compensation funds to protect users from cyber attacks, thereby reducing the risk of financial crime.

3. Vietnam Crypto Assets Tax Policy and Its Latest Developments

The evolution of Vietnam's Crypto Assets tax policy has almost coincided with Vietnam's regulatory policies on Crypto Assets. In the early stages, due to the ambiguous and contradictory characterization of Crypto Assets by Vietnamese authorities, the regulatory policies were rough and one-size-fits-all, making it unrealistic to impose taxes on Crypto Assets. However, the rapid expansion of Crypto Assets trading volume forced the government to confront its legal status, compelling Vietnamese authorities to conduct research on Crypto Assets. Especially entering 2024, the government has shown a stronger urgency in establishing a clear legal framework.

3.1 Currently, Vietnam's Crypto Assets trading is still in a tax ambiguity.

For a long time, due to the lack of clear legal definitions and regulatory frameworks, cryptocurrency trading in Vietnam has been in a tax gray area. The letter from the Vietnamese Ministry of Finance in 2016, while not prohibiting cryptocurrency trading,