Vietnam's Two-Track Digital Asset Architecture: What the VIFC Sandbox Permits That the National Pilot Does Not
Vietnam runs two parallel digital asset regimes — a restrictive national pilot and a flexible VIFC sandbox. Here is what each permits and why it matters.
Vietnam now operates two parallel regulatory tracks for digital assets, and most international commentary treats them as one. The national pilot programme under Resolution No. 05/2025/NQ-CP is restrictive by design — high capital thresholds, Vietnamese-đồng-only settlement, no stablecoin issuance. The VIFC sandbox authority under Resolution 222 is structurally different: it permits instrument types the national track explicitly excludes. For international firms evaluating market entry, confusing the two tracks means misjudging what Vietnam actually permits and where.
The national pilot: what Resolution 05 actually permits#
The legal foundation was laid in two stages. The Law on Digital Technology Industry 2025, enacted 14 June 2025 and effective 1 January 2026, formally recognised digital assets as a category of property under the Civil Code — the first time Vietnam had done so. Resolution No. 05/2025/NQ-CP, issued 9 September 2025, then established a five-year pilot programme (2025–2030) for the issuance, trading, and supervision of crypto assets under the Ministry of Finance.
The constraints are substantial:
- Eligible operators: Vietnamese-incorporated companies only. No foreign-domiciled entity can hold a licence directly.
- Capital requirement: VND 10 trillion minimum charter capital — approximately $380–400 million. This is higher than most regional peers and effectively restricts entry to bank-affiliated or conglomerate-backed entities.
- Ownership limits: Maximum 49% foreign ownership, with at least 65% institutional shareholding required.
- Settlement currency: Vietnamese đồng only. No USD or foreign-currency settlement is permitted.
- Stablecoin prohibition: The Law on Digital Technology Industry explicitly excludes "digitised forms of fiat currency" from the crypto asset definition, prohibiting stablecoin issuance during the pilot phase.
- Licence cap: Five licences maximum. Five companies have passed the first qualification stage: VIX Digital Asset Exchange (VIXEX), Loc Phat Vietnam Crypto Asset Exchange (LPEX), Vietnam Prosperity Crypto Asset Exchange (CAEX), Techcom Digital Asset Exchange (TCEX), and Vietnam Digital Assets JSC.
The Ministry of Finance began accepting applications on 20 January 2026 under Decision No. 96/QĐ-BTC. In parallel, Hanoi has moved to block offshore exchange access — pushing Vietnam's substantial retail user base toward these licensed domestic platforms.
The national pilot is designed for a specific purpose: bringing domestic crypto trading onshore, under Vietnamese regulatory supervision, through well-capitalised incumbents. It is not designed for international firms seeking to offer stablecoin products, tokenisation platforms, or DeFi infrastructure. The instrument types that interest those firms are either explicitly excluded or structurally impractical under Resolution 05's constraints.
The VIFC sandbox: a structurally distinct pathway#
Resolution 222 grants VIFC governing bodies autonomous authority to establish sandbox frameworks that operate outside the national pilot's enumerated categories. This is not a carve-out within the national framework — it is a separate legal track with its own authorising legislation.
The distinction matters because the national fintech sandbox — Decree 94/2025 — is itself limited to three use cases: credit scoring, open API data sharing, and peer-to-peer lending. Blockchain and digital asset conversion products do not qualify under Decree 94. This means there is no national-level sandbox pathway for the activities most relevant to international digital asset firms. The VIFC sandbox is not merely preferable; for stablecoin conversion and novel digital asset instruments, it is the only current regulatory pathway in Vietnam.
How the two tracks diverge#
The practical differences are stark:
| National pilot (Resolution 05) | VIFC sandbox (Resolution 222) | |
|---|---|---|
| Stablecoin conversion | Prohibited — digitised fiat excluded from definition | Permitted — Basal Pay converts USDT to VND |
| Settlement currency | VND only | Foreign currency use permitted for VIFC members |
| Foreign ownership | 49% maximum | No equivalent restriction stated |
| Capital floor | VND 10 trillion (~$380 million) | No equivalent capital requirement stated |
| Licensing authority | Ministry of Finance | VIFC governing body (e.g., Da Nang People's Committee) |
| Scope | Exchange operation for listed crypto assets | Sandbox can pilot activities outside national enumerated categories |
| Liability protection | Standard regulatory liability | Administrative and civil liability relief for sandbox participants where damage arises from objective causes |
This table is not academic. It determines which firms can enter, what products they can offer, and under whose authority they operate.
Basal Pay: the worked example#
Da Nang's People's Committee approved Basal Pay — developed by AlphaTrue Solutions JSC — under Decision No. 1181/QĐ-UBND. It is the first licensed blockchain payment solution in Vietnam, and its approval demonstrates precisely how the VIFC sandbox track works in practice.
Basal Pay converts Bitcoin and USDT directly to Vietnamese đồng, reportedly at roughly 30% lower cost than traditional remittance channels. The 36-month trial operates under Politburo Resolution No. 57/NQ-TW's "controlled pilot" mechanism and must comply with Financial Action Task Force (FATF) Travel Rule standards.
Two features of this approval are analytically significant.
First, Basal Pay converts USDT — a stablecoin — to VND. Under the national framework, stablecoins are excluded from the crypto asset definition entirely. Basal Pay's core function is legally impossible under Resolution 05. The approval came through the VIFC sandbox authority, not the national pilot or the national fintech sandbox.
Second, Da Nang's People's Committee issued the approval without reference to the national Resolution 05 framework. LNT Partners, in their analysis of the decision, explicitly noted that Basal Pay operates outside Decree 94's scope. The legal basis is Resolution 222's grant of autonomous sandbox authority to VIFC governing bodies — a distinct chain of authority from the Ministry of Finance-administered national pilot.
This is not a technicality. It establishes a precedent: VIFC governing bodies can approve digital asset activities that the national framework does not contemplate or actively excludes. For firms evaluating Vietnam market entry, Basal Pay is the proof of concept that the two-track architecture functions as designed.
What the VIFC track offers — and what remains unconfirmed#
LNT Partners describes the VIFC as "the principal jurisdictional gateway for digital asset-related activities" in Vietnam. This framing comes from law firm analysis rather than a primary government instrument, but the directional assessment is supported by the structural evidence. The VIFC framework offers:
- Preferential corporate income tax for priority sectors, which explicitly include DeFi, tokenisation, and stablecoin services
- Foreign currency use under Decree 329 and Circular 72 — directly relevant given the VND-only constraint in the national pilot
- IFRS-based accounting standards — a practical requirement for international firms that cannot operate under Vietnamese Accounting Standards
- Liability relief for sandbox participants where damage arises from objective causes during the pilot process
However, important questions remain unanswered. The VIFC sandbox's capital requirements, if any, have not been publicly specified for digital asset firms. The scope of permissible sandbox activities has been demonstrated by Basal Pay but not comprehensively enumerated. And the relationship between VIFC sandbox approvals and the national regulatory architecture — particularly whether sandbox successes graduate into permanent licences, and under whose authority — is untested.
The Binance MoU signals that major international firms are treating the VIFC as the relevant entry point, but memoranda of understanding are not licences. The distance between an MoU and operational approval remains significant.
Regional context: Vietnam's capital floor in perspective#
Vietnam's two-track architecture is distinctive in Southeast Asia, but the broader regional direction is convergent. During mid-2025, Singapore's Monetary Authority moved to force unlicensed exchanges to exit while expanding its own licensing regime. Thailand similarly moved to block major foreign platforms around the same period. Indonesia transferred crypto oversight from commodities regulator Bappebti to financial supervisor OJK — treating crypto as a financial product rather than a commodity, a trajectory similar to Vietnam's.
What sets Vietnam apart is the capital floor. The national pilot's VND 10 trillion requirement (~$380–400 million) is substantially higher than regional peers. This is deliberate: it channels national-track licences toward bank-affiliated entities with the balance sheets to absorb the requirement. It also means that the VIFC sandbox — which carries no stated equivalent threshold — becomes the de facto entry point for international firms that cannot or will not meet the national capital floor.
The Philippines SEC extended authority over crypto through 2025 consumer protection rules, and Singapore's regime is more mature and more open, but also more contested. Vietnam's approach — restricting the national track while opening a parallel VIFC track — is an explicit bet that zonal regulation can attract international capital without liberalising the domestic retail market.
What this means for international firms#
The practical implications are direct.
If you are a domestic exchange operator — the national pilot is your track. Meet the VND 10 trillion capital floor, secure one of five licences, and operate in Vietnamese đồng. The regulatory path is clear, if expensive.
If you are an international firm interested in stablecoin products, tokenisation, or DeFi infrastructure — the national pilot is structurally closed to you. Foreign ownership is capped at 49%, stablecoins are excluded, and the capital floor is prohibitive for most non-bank entities. The VIFC sandbox is the operative pathway, and the practical guide for fintech and digital asset firms outlines the entry mechanics.
If you are a remittance or payments firm — Basal Pay's approval demonstrates that crypto-to-fiat conversion is achievable through the VIFC sandbox, with FATF Travel Rule compliance as a baseline requirement. The 30% cost reduction over traditional channels is a commercial proof point, not merely a regulatory one.
If you are evaluating Vietnam against other ASEAN jurisdictions — the relevant comparison is not Vietnam's national pilot versus Singapore's MAS regime. It is the VIFC sandbox versus Singapore's MAS regime. The national pilot is a domestic market structuring exercise. The VIFC sandbox is the international-facing regulatory product.
What to watch#
Three developments will determine whether the two-track architecture delivers on its structural promise.
Sandbox-to-licence graduation. Basal Pay's 36-month trial will end. The mechanism for converting a successful sandbox pilot into a permanent licence — and whether that licence operates under VIFC or national authority — has not been defined. This is the most consequential open question in the framework.
VIFC sandbox terms for digital asset firms. Capital requirements, permissible activities, and supervisory expectations for VIFC sandbox participants beyond Basal Pay have not been publicly specified. The next approvals will reveal whether the Basal Pay precedent generalises or was a one-off.
Offshore blocking enforcement. Vietnam is actively pushing retail users away from offshore exchanges and toward licensed domestic platforms. The effectiveness of this enforcement — and whether it extends to VIFC-sandbox-approved platforms serving international users — will shape the commercial viability of both tracks.
The two-track architecture is not accidental. Vietnam has deliberately constructed a restrictive domestic market alongside a flexible international zone. For firms that understand which track applies to them, the regulatory picture is considerably clearer than the single-narrative coverage suggests.
This article reflects the regulatory position as of 18 April 2026. We will update it as new sandbox approvals, licensing decisions, or implementing instruments are issued.
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