The rules of the game are changing: the current status of centralized exchange licenses in Vietnam.

This article is written by Tiger Research, providing an in-depth analysis of the new regulations for cryptocurrency exchanges in Vietnam: under the minimum registered capital threshold of $380 million, fierce competition for limited licenses has emerged between international giants like Binance and Bybit and local institutions.

Key Summary

• The new regulatory framework in Vietnam sets extremely high entry barriers, only large banks, securities companies, or global exchanges with strong partners are likely to meet the standards.
• Although seven local enterprises 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 high-ranking officials of the Vietnamese government, indicating that foreign exchanges will share the market cake with a few local licensed institutions.

1. New Regulatory Era: Vietnam's Digital Asset Market Moves Towards Standardization

In 2025, Vietnam's digital asset market will undergo a decisive transformation. After years of regulatory ambiguity, the government has successively introduced 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, which is scheduled to be officially implemented on January 1, 2026. This law clearly establishes the independent status of digital assets at the legal level for the first time, distinguishing them from securities and fiat currency instruments, and providing a legal basis for subsequent taxation, anti-money laundering regulation, and law enforcement authority, with specific details to be further clarified through implementing regulations.

The second key measure is the “Regulatory Sandbox Decree” that will take effect on July 1, 2025. Led by the State Bank of Vietnam, this sandbox mechanism provides a testing environment for financial innovation. Although not specifically designed for crypto assets, it is expected to create regulatory synergy with the exchange licensing system through core requirements such as anti-money laundering, customer identification verification, and settlement. The most immediate impact comes from the Resolution No. 05/2025/NQ-CP issued on September 9, 2025, which officially launches a five-year pilot program for the issuance and trading of virtual assets. This becomes the first practical framework for exchanges to operate legally in Vietnam. The key limitation is that during the pilot phase, only domestic enterprises in Vietnam can apply for operator licenses, while foreign exchanges must participate indirectly through joint ventures or by providing technology, compliance systems, and liquidity support.

The series of combined measures demonstrate the government's intentions: to gradually incorporate digital asset activities into the domestic system under strict regulation. The policy direction clearly favors local control, aligns with international anti-money laundering standards, and is deeply tied to the strategic goal of establishing the Da Nang regional financial center.

For institutions, the core issue is that Vietnam has bid farewell to the era of regulatory vacuum, which is a positive signal. However, the high threshold for licensing and restrictions on foreign capital indicate that the level of openness remains limited. The next 12-18 months will witness whether Vietnam can grow into a structural market or merely remain a policy testing ground.

2. High threshold for licensed operation

The resolution No. 05/2025/NQ-CP issued on September 9, 2025, sets strict entry requirements for Vietnam's five-year pilot program for Crypto Assets: only Vietnamese enterprises registered under the Enterprise Law are eligible to apply as operators.

Licensed institutions must maintain a minimum statutory capital of 100 trillion Vietnamese dong (approximately 3.8 billion USD), which must be fully paid in Vietnamese dong. At least 65% of the capital must come from institutional shareholders, and more than 35% of that portion of shares must be jointly funded by at least two of the following types of organizations: commercial banks, securities companies, fund management companies, insurance companies, or technology enterprises. Institutional shareholders must also meet the requirement of having a record of profitability for two consecutive years, and their audited financial reports must receive an unqualified opinion.

The proportion of foreign capital holdings is strictly limited to within 49% of the statutory capital, ensuring that operational control is held by local entities. In addition, licensed institutions must meet strict human resource and infrastructure requirements: the CEO must have at least two years of experience in the financial industry, the technical director must have five years of relevant IT qualifications, and at least 10 employees with cybersecurity certifications and 10 employees with securities qualifications must be allocated. The technical systems must meet the highest national information security Level 4 certification standards in the financial industry.

Although this framework demonstrates the government's determination to regulate the market, its requirements pose challenges even for mature financial institutions. If the scope is expanded in the future to include wallet services, GameFi projects, or medium-sized exchanges, the vast majority of native crypto companies will find it difficult to meet the standards.

KyberSwap restricts access for users in Vietnam. Source: KyberSwap

It is worth noting that local Vietnamese projects such as KyberSwap and Coin98 have proactively suspended domestic operations. In practice, a hybrid model is most likely to form: banks, brokerages, insurance companies, and tech giants will constitute the licensed core, while Web3 projects will participate as technology and service providers. In this ebb and flow, market dominance will tilt toward licensed institutions, and startups and native crypto projects may be marginalized.

The scope of business is also strictly limited: only asset-backed token issuance and spot trading are allowed, and settlement must be in Vietnamese Dong. The crypto assets payment function remains prohibited, and derivatives and leverage trading are not open. Compared to pioneers such as the United States, Singapore, and Hong Kong, the permissible business scope in Vietnam is clearly narrower.

3, The confrontation between local and international forces

3.1 Local Participants Layout

A number of Vietnamese companies have taken precautions and registered as “digital asset exchanges” in order to seize the opportunity after the implementation of the new policy. However, the current capital scale and shareholding structure of these institutions are still far from the rigid requirements of Resolution 05/2025.

For institutional investors, there are three observations worth noting. First, the capital gap is decisive. The capitalization levels of all current participants range from 2 billion VND to 1.47 trillion VND, far below the legal minimum requirement of 100 trillion VND. Without large-scale injections from banks, securities companies, or insurance companies, most of these entities will not meet licensing qualifications.

Secondly, institutional anchoring will determine who can survive. The resolution requires at least 65% institutional ownership, including at least 35% shares from two banks, securities companies, insurance companies, or technology enterprises. This clause clearly favors participants who are already connected with major financial institutions such as SSI, VIX, Techcom, HD, and MB, while putting fintech-led vehicles like DNEX or CAEX at a disadvantage, unless they can attract more powerful partners.

Finally, market expectations indicate that licenses 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 will inevitably be excluded. For global exchanges evaluating the Vietnamese market, this underscores the importance of forming alliances early with the most credible domestic partners.

3.2 Global Players and Government Strategic Interaction

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

Global exchanges are actively building communication bridges 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 extended a personal invitation to Binance to establish a regional headquarters in Da Nang and participate in the construction of a licensed digital asset exchange for Vietnam's international financial center. He also invited Teng, who previously led the Abu Dhabi Global Market, to serve as a senior advisor to Vietnam's financial center. This move was announced through official government channels, sending a clear policy signal.

Binance CEO Richard Teng met with Vietnamese leaders in Da Nang. Source: Binance

At the same time, the Da Nang People's Committee signed a memorandum of cooperation with Binance, establishing a strategic partnership in the field of blockchain and crypto assets. This means that Binance has both high-level endorsement and a framework for cooperation with the local government.

Bybit is also making aggressive moves. On September 17, 2025, it signed a tripartite memorandum with the Da Nang People's Committee, the Abu Dhabi Blockchain Center, and Verichains, covering liquidity provision, infrastructure security, and ecological connectivity, precisely aligning with Vietnam's regulatory goals. Although it hasn't reached the high-level meeting level of Binance, it lays a practical foundation for its participation in the construction of an international financial center.

The current situation shows that Binance and Bybit have seized the initiative in the competition among global exchanges in Vietnam. If the rumors are true and only 5 licenses are issued, with 2 seats reserved for international exchanges, then local companies are left with only 3 slots. Faced with at least 7 competitors ready to pounce, local institutions must accelerate their efforts to prove their strength and institutional background in order to secure the remaining positions.

This layout also triggers a chain of thoughts: what will happen to global exchanges like BingX and MEXC, which have already occupied the mainstream of the retail market in Vietnam? If these exchanges, which serve Vietnamese users through offshore platforms, fail to conduct government relations in a timely manner, they may be marginalized in the licensed market. Unless they quickly form alliances with approved local entities or receive special invitations, their business will continue to operate outside of regulation and may face regulatory risks after the licensed market matures.

4. Strategic Breakthrough: The Entry Path of the “CEX Tiger” Virtual Case

Under the new system, what options are available for projects seeking to enter Vietnam? Consider a hypothetical case “CEX Tiger”, a global exchange planning to expand into Vietnam, and what strategies would be the most feasible.

The first and most important decision is to choose a partner. Foreign exchanges cannot obtain licenses directly and must ally with strong domestic institutions. It is crucial to determine which Vietnamese banks, securities companies, or insurance companies are most likely to obtain one of the limited licenses. The choice of partner will determine market access, compliance status, and long-term scalability.

Once the partners are secured, the next step is to define the operational model. A hybrid structure is needed: the Vietnamese partner holds the license and regulatory responsibilities, while CEX Tiger contributes technology, liquidity, and operational expertise. The joint venture becomes a formal entity, with domestic institutions serving as the legal and regulatory front, and foreign exchanges operating the underlying services.

Business expectations must also be calibrated. This framework limits activities to spot trading, Vietnamese Dong settlement, and limited investor participation. This is not a market designed for immediate trading volume or revenue driven by derivatives. Instead, the strategic objective should be to ensure early presence, build regulatory goodwill, and establish legitimacy before potential future liberalization.

However, the competition will be fierce. If the two licenses are allocated to Binance and Bybit, there will only be three left for domestic institutions. For newcomers, the real issue is not whether Vietnam is attractive - the market growth and user base make this quite clear - but whether it can secure a trustworthy domestic partner and whether that partner is willing to cooperate. Missing the first round of licenses may delay entry until the framework expands.

For exchanges like CEX Tiger, Vietnam should be viewed as a long-term strategic foothold rather than a short-term profit source. The key to success lies in: selecting local partners wisely, being content with a minority equity position, and deeply cultivating the most growth-potential crypto markets in Asia in advance.

From the user's perspective, the challenges are more complex. Vietnamese users are accustomed to global trading platforms. Even with obtaining a license, new entrants will still face multidimensional tests such as security standards, asset categories, and platform stability. A license brings compliance, but it cannot automatically translate into user trust and market share.

**The ultimate strategic choice lies ahead for CEX Tigers: do they join the competition for licenses with local partners, or do they stick to the regulatory periphery to maintain existing users while closely tracking policy developments? This strategic game related to the Vietnamese market has just begun. **