Directive 05/CT-TTg: Vietnam's Crypto Framework Development and Its Strict New Rules

On September 9, 2025, Vietnam’s government dropped a regulatory bomb: Resolution No. 05/2025/NQ-CP, also known as Directive 05/CT-TTg. It didn’t just tweak the rules-it rewrote them. For the first time, cryptocurrency exchanges operating in Vietnam must now meet a capital requirement of 10 trillion VND (roughly $379 million USD). That’s not a suggestion. It’s a hard wall. And it’s reshaping everything about how crypto works in the country.

What Exactly Is Directive 05/CT-TTg?

This isn’t a guideline. It’s a legal framework. Signed by Deputy Prime Minister Ho Duc Phoc, it’s part of Vietnam’s broader Law on Digital Technology Industry passed in June 2025. The goal? To bring order to a market that had grown wildly without oversight. With an estimated 21 million active crypto users, Vietnam had become one of the top two countries globally for adoption-behind only Ukraine. But most of those trades happened on unregulated platforms. No KYC. No accountability. No protection when things went wrong.

Now, the Ministry of Finance is the only body allowed to issue licenses. And no exchange can operate without one. The rules are clear: you must prove you have at least 10 trillion VND in capital. At least 65% of that-6.5 trillion VND-must come from institutional investors based in Vietnam. Foreign investors? They can own up to 49%. That’s not a small barrier. It’s a gatekeeper.

Why the $379 Million Cap?

Why such a high number? The answer lies in history.

In 2022, during the crypto winter, 15 unregulated Vietnamese exchanges collapsed. Over half a million users lost money. Some platforms vanished overnight. Others froze withdrawals for months. The public outcry was loud. The government couldn’t ignore it.

Dr. Nguyen Minh Tuan, director of Vietnam National University’s Economic Policy Institute, put it plainly: “The capital requirement, while seemingly high, is necessary to prevent the market instability we witnessed.” He’s right. A $190,000 exchange like the one run by Reddit user ‘HanoiTrader88’-which had served 5,000 users for two years-can’t survive under this rule. That’s not a mistake. It’s intentional. The government wants only deep-pocketed players who can absorb losses, survive crashes, and stay solvent.

But there’s a catch. The World Bank warned that this might displace 18-20 million users. Why? Because most exchanges won’t qualify. Industry analysts estimate only 3-5 licenses will be granted in the first year. That means 85% of today’s users might suddenly have nowhere to trade legally.

VND-Only Transactions: No USD, No EUR, No Stablecoins

Here’s where it gets even more restrictive. All trades must happen in Vietnamese dong (VND). No direct USD, no EUR, no Bitcoin-to-USDT swaps. That’s huge.

Why? Because the State Bank of Vietnam has long feared capital flight. In 2025, an estimated $10.2 billion in crypto transactions flowed through Vietnam-87.4% of it unregulated. That’s money leaving the country, bypassing banking controls. By forcing everything into VND, the government keeps every transaction traceable, taxable, and controllable.

But here’s the real problem: stablecoins. They made up 63.8% of all crypto trades in Vietnam in 2025. USDT, USDC, BUSD-they’re the glue that holds global crypto markets together. But under this law, you can’t issue or trade any stablecoin backed by fiat currency. That’s a direct ban. And it’s a massive blow to traders. Why? Because converting VND to USDT was the easiest way to hedge against inflation or move value quickly. Now, that door is shut.

Platforms will have to build new asset-backed tokens-maybe gold-backed or commodity-backed-but that’s untested territory. No one in Vietnam has done it at scale. And it’s not clear if users will accept it.

Technical Requirements: Blockchain, KYC, and Surveillance

It’s not just about money. You need tech.

Every licensed exchange must use blockchain technology that complies with Vietnam’s National Cryptography Standard (TCVN 13057:2025). That’s a government-approved system called NDAChain, launched in July 2025. All transactions must feed into it in real time.

Plus, KYC and AML protocols must meet the highest local standards-matching Vietnam’s 2023 Anti-Money Laundering Law. That means verifying every user’s identity, tracking every transaction, and reporting anything suspicious to the State Bank of Vietnam.

And yes, the government will see it all. There’s no privacy here. The system is designed for surveillance, not anonymity. That’s a big shift from the libertarian roots of crypto. For many users, that’s a dealbreaker.

How Does Vietnam Compare to Its Neighbors?

Let’s put this in context.

Vietnam’s rules are the strictest in the region. Thailand’s requirement is less than 4% of Vietnam’s. Singapore’s is flexible and open. Indonesia bans retail trading entirely. Vietnam walks a middle path: it allows retail trading, but only under extreme financial control.

And it’s working-sort of. While Thailand has licensed 12 exchanges, Vietnam might only license 3-5 in the first year. That’s not innovation. That’s consolidation. And it’s happening fast.

Who Wins? Who Loses?

On Reddit, the debate is fierce.

‘HanoiTrader88’ wrote: “This kills my small exchange business overnight.” He’s not alone. Thousands of small operators who built loyal customer bases with low fees (0.15% vs. global 0.25%) are now out of business.

But then there’s ‘SaigonVC’: “Finally some regulation! Last year I lost $455,000 when BitViet disappeared.” For institutional investors, this is a win. They want safety, not speed. They want to know their money won’t vanish.

And the users? A CoinGeek survey found 68.3% support regulation for security. But 79.6% think the capital requirement is too high. And 41.2% say they’ll move to offshore platforms if local options shrink.

That’s the real risk: a brain drain. If you can’t trade legally at home, you’ll go elsewhere. And Vietnam will lose its position as a crypto adoption leader.

What’s Next? The Six-Month Clock Is Ticking

The law took effect immediately. But there’s a grace period: six months after the first license is issued. That’s the trigger. No one knows when that will happen. The Ministry of Finance says applications open within 30 days. First licenses? Maybe 90-120 days after that.

That means the clock starts ticking in early 2026. By mid-year, unlicensed platforms must shut down. That’s not a soft landing. It’s a cliff.

Compliance costs? $1.9 million to $7.6 million per platform, according to legal analysts. That’s not just capital. That’s legal fees, tech upgrades, audits, staff training. Most small exchanges can’t afford it.

And tax rules? They’re 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. That’s low-but it’s still a tax. And it means every trade is now tracked by the state.

Will This Work?

It’s too early to say. But the stakes are high.

Vietnam wants to grow its digital economy from 9.5% of GDP to 20% by 2030. Regulated crypto is supposed to contribute 1.2-1.8% of that. But if users flee, if innovation dies, if platforms can’t operate, that goal vanishes.

The government is betting that control equals stability. That heavy capital requirements prevent fraud. That banning stablecoins protects the currency. That surveillance ensures compliance.

But crypto was built on openness. On decentralization. On trustless systems. Vietnam’s model is the opposite. It’s centralized. It’s controlled. It’s bureaucratic.

Will it work? Maybe. But at what cost?

One thing is certain: the era of unregulated crypto in Vietnam is over. The next chapter will be written by a handful of well-funded players, under strict government watch. For the average user, it might mean less freedom-but more safety. For entrepreneurs? It might mean the end of the dream.

What Should Users Do Now?

If you’re a casual trader: keep your funds on a licensed exchange once they launch. Avoid unlicensed platforms after mid-2026-they’ll be shut down, and your money could disappear.

If you run a small exchange: start planning your exit. The capital requirement is impossible to meet. Consider selling your user base to a licensed player or moving your operations abroad.

If you’re an investor: look for opportunities in compliance tech. The need for KYC systems, blockchain integration, and audit tools is exploding. This isn’t the end of crypto in Vietnam-it’s the beginning of a new, tightly controlled phase.

The game has changed. The rules are written. Now it’s up to everyone else to adapt-or get left behind.