SBV Vietnam: Digital Assets Framework

Vietnam's SBV-led digital asset pilot framework under Resolution 100/NQ-CP, the 2026-2027 Digital Asset Law, and what to do today as an issuer or business.

An editorial illustration of digital assets moving along a Vietnamese river through policy checkpoints
An editorial illustration of digital assets moving along a Vietnamese river through policy checkpoints

TL;DR

Vietnam ranks in the global top three for grass-roots crypto adoption, but its regulatory framework is still being finalised. Resolution 100/NQ-CP (2025) established a digital-asset pilot framework led by the State Bank of Vietnam (SBV), the Ministry of Finance (MOF), and the Ministry of Information and Communications (MIC). The full Digital Asset Law is expected to pass in 2026-2027. Until then, stablecoins occupy a tolerated-but-unregulated zone — legal to hold and trade peer-to-peer, but not legal tender and not permitted as a payment instrument for goods and services.

The regulatory framework

For most of the past decade, Vietnamese law did not recognise digital assets as a distinct category. The SBV's posture was simple: crypto is not legal tender, and using it to pay for goods or services is prohibited under Decree 80/2016/ND-CP on non-cash payments. Holding and peer-to-peer trading were neither explicitly permitted nor prohibited.

Resolution 100/NQ-CP (2025) changed the trajectory. It directs the SBV, MOF, and MIC to:

  • Define a clear regulatory perimeter for digital assets including stablecoins
  • Pilot a licensing framework for digital asset service providers
  • Set tax treatment for digital asset gains and transactions
  • Coordinate AML/CFT with Vietnam's Financial Intelligence Unit

A formal Digital Asset Law is being drafted for National Assembly consideration in 2026-2027.

Current de facto rules

Under the pilot framework as it operates today:

  • Holding: legal
  • Peer-to-peer trading: legal (widely active on Binance P2P, Remitano, OTC desks)
  • Payment for goods and services: not permitted; merchants accepting crypto as payment can be fined under Decree 80/2016
  • Cross-border transfer: a grey area — not banned, but large outflows may trigger AML reporting

There is no fully VND-pegged stablecoin in general retail circulation as of 2026. Several projects are reportedly in pilot under the SBV framework but none has reached broad availability.

For stablecoin issuers

Issuing a stablecoin from a Vietnamese entity is not yet feasible under the existing pilot — the framework is still being built. Foreign issuers offering tokens that Vietnamese users hold or trade peer-to-peer are not directly regulated, but should anticipate:

  1. A future licensing regime under the Digital Asset Law (2026-2027)
  2. AML/CFT obligations aligned with FATF standards (Vietnam is a FATF observer)
  3. Tax treatment likely modelled on existing financial-asset rules

For businesses

Vietnamese businesses cannot accept stablecoins as payment for goods or services. They may, however:

  • Hold stablecoins as a treasury asset
  • Receive stablecoins via cross-border B2B settlement (subject to AML reporting)
  • Trade stablecoins peer-to-peer

The US → Vietnam corridor for freelancer payments is especially active — many Vietnamese freelancers are paid in USDT by overseas clients and convert to VND through peer-to-peer markets.

For developers and integrators

  • Vietnam is a high-volume retail market with limited licensed on-ramp infrastructure
  • Geo-fence payment products until the Digital Asset Law is in force
  • Treat Vietnam as a strategically important corridor with regulatory uncertainty — engage early with the SBV's digital asset working group if planning a launch

Adoption stats

  • Over 17 million Vietnamese users have engaged with crypto (Chainalysis, 2024)
  • Peer-to-peer USDT volume in the US → Vietnam corridor has grown approximately 5x since 2022
  • Approximately 12% of Vietnamese internet users have held a digital asset

What to watch in 2026-2027

  • Digital Asset Law draft released for public consultation H1 2026
  • National Assembly vote expected H2 2026 or H1 2027
  • First SBV-licensed digital asset service provider under the pilot framework
  • VND-pegged stablecoin pilot — at least two projects are in late-stage SBV engagement

Where to learn more