Crypto Trading vs Payment in Vietnam: What’s Legal Under the 2025 Rules

Before September 2025, buying Bitcoin or sending Ethereum to a friend in Vietnam was a legal gray zone. You could do it, but no one knew exactly how the government would react. That changed with Resolution No. 05/2025/NQ-CP, signed on September 9, 2025, and the Digital Technology Industry Law passed in June 2025. Now, Vietnam has one of the clearest, most restrictive crypto frameworks in Southeast Asia-and the difference between crypto trading and crypto payment is the key to staying legal.

Trading Crypto in Vietnam: It’s Not What You Think

You can’t just open a Binance account and start trading. Under the new rules, all crypto trading must happen on platforms licensed by Vietnam’s Ministry of Finance. And those licenses aren’t easy to get. A company needs at least 10 trillion VND-around $379 million-in capital. Sixty-five percent of that must come from institutional investors, not retail traders. Foreign companies can own no more than 49% of the platform. That means only big, well-funded Vietnamese financial firms will be allowed to run exchanges.

The system doesn’t just control who runs the exchanges-it controls how you trade. Every transaction must be done in Vietnamese dong (VND). If you want to buy Ethereum, you deposit VND. If you sell Bitcoin, you get VND back. There’s no direct crypto-to-crypto trading allowed on licensed platforms. This isn’t about convenience-it’s about control. The government wants to track every dollar flowing in and out of digital assets.

The six-month grace period after the first license is issued (expected early 2026) gives users time to move. After that, using any unlicensed exchange is illegal. For the estimated 20 million crypto users in Vietnam, that means choosing between a regulated, restricted platform or risking fines or worse.

Payment With Crypto: The Big Unknown

Here’s where things get murky. The law says crypto can be used for payment-but it doesn’t say how, when, or under what conditions. You won’t find a single line in Resolution 05/2025/NQ-CP that says: “You can pay for coffee with Bitcoin.” Or: “Businesses must accept crypto as payment.”

The mandatory VND pairing rule creates a natural barrier. If every trade must convert to VND, then using crypto directly to pay for goods or services becomes technically difficult. Imagine trying to pay your landlord with Ethereum. You’d need to sell it on a licensed exchange first, wait for the VND to settle, then transfer it to your landlord. That’s not payment-it’s a two-step financial transaction.

There’s no mention of peer-to-peer crypto payments either. Can you send Dogecoin to your cousin in Ho Chi Minh City? The law doesn’t say you can’t. But it doesn’t say you can, either. That silence is intentional. The government is holding back on payment use cases until it figures out how to monitor them without triggering money laundering risks.

For now, businesses that accept crypto for goods or services are operating in legal limbo. If you run a small shop and take USDT as payment, you’re not breaking any explicit rule-but you’re also not protected by any law. If a dispute arises, courts won’t recognize crypto as legal tender. You’re on your own.

What Counts as a Crypto Asset?

To understand the rules, you need to know what’s even being regulated. The Digital Technology Industry Law defines three types of digital assets:

• Virtual assets-like in-game coins or loyalty points
• Crypto assets-Bitcoin, Ethereum, stablecoins, and other decentralized digital tokens
• Other digital assets-NFTs, utility tokens, and blockchain-based credentials

Only crypto assets are subject to the trading restrictions. Virtual assets (like a game currency) and NFTs aren’t covered by the same rules. That’s why you can still buy a digital art piece as an NFT without triggering exchange licensing rules. But if you start trading that NFT for Bitcoin, you’re now in trading territory-and you need a licensed platform.

The law also makes it clear: crypto assets are not money. They’re not securities. They’re not digital versions of the Vietnamese dong. They’re a new category-digital property. That means you can own them, inherit them, and sell them. But you can’t use them like cash.

Why the VND-Only Rule Matters

The requirement that all trades go through Vietnamese dong isn’t just a technical detail. It’s the core of Vietnam’s entire strategy. By forcing every transaction through the national currency, the government keeps control over capital flows. It can track how much money is entering and leaving the crypto market. It can freeze accounts if suspicious activity is detected. It can tax gains by linking them to VND conversions.

This approach is the opposite of what you see in places like the U.S. or Singapore, where crypto-to-crypto trading is common and stablecoins are used for payments. Vietnam isn’t trying to be innovative-it’s trying to be safe. The $379 million capital requirement and the VND-only rule are both designed to make it nearly impossible for small players or foreign operators to enter the market.

It’s also why crypto mining isn’t mentioned in the law. Mining doesn’t involve trading or payments-it’s just creating new tokens. The government hasn’t decided whether to allow it, ban it, or regulate it. That silence tells you everything: mining is too unpredictable to include in the current framework.

What Happens After January 1, 2026?

That’s the date the Digital Technology Industry Law fully takes effect. After that:

• Only licensed platforms can offer crypto trading
• All trades must be in VND
• Unlicensed exchanges are illegal for Vietnamese users
• Crypto assets are legally recognized as property
• Payments with crypto remain legally undefined

The five-year pilot program (running until September 2030) means the rules can change. The government will monitor how the market reacts. If trading volume stays low because of the high barriers, they might lower the capital requirement. If people start using crypto for payments anyway, they might create new rules to allow it under strict conditions.

For now, the message is clear: if you want to trade crypto in Vietnam, you do it on a government-approved platform, using Vietnamese dong. If you want to pay for something with crypto, you’re on your own.

What Should You Do?

If you’re a trader: switch to a licensed platform as soon as one opens. Don’t wait until the six-month grace period ends. You don’t want to be caught using an unlicensed exchange after January 2026.

If you’re a business: don’t start accepting crypto as payment yet. There’s no legal protection. If a customer disputes a transaction, you can’t go to court and say, “They paid me in Bitcoin.” The law won’t back you up.

If you’re a regular user: understand that crypto in Vietnam is no longer a tool for freedom or innovation. It’s a controlled asset. You can own it. You can trade it-within strict limits. But you can’t use it like money.

The government isn’t trying to kill crypto. It’s trying to cage it. And for now, the cage has very specific rules.

What’s Next?

The next six months will be critical. As licensed exchanges launch, watch how they operate. Will they offer simple interfaces? Will they support wallet transfers? Will they allow users to hold crypto outside the platform? These details will show whether the system is designed for control-or for adoption.

The real test will come in 2027, when the first tax rules are released and the first penalties are applied. If the government starts cracking down on small traders or businesses using crypto for payments, it will confirm that their goal isn’t integration-it’s containment.

For now, Vietnam has chosen a path few countries have taken: strict control over a technology that was built to be free. Whether that works-or whether it pushes users back underground-will determine the future of crypto in Southeast Asia.