This blog post was co-authored by Dea Markova and Ben Wilton.
As a portion of its economy, Vietnam is one of the most active retail digital asset markets in the world. It is now building the rules to onshore all this activity. We think it is one of the most promising markets in ASEAN for bank-grade infrastructure, and we expect custody to be the first place our technology stack is deployed.
The market opportunity
While Vietnam’s GDP per capita still trails most of its Southeast Asian neighbours, its digital asset adoption tops world rankings, especially relative to the size of its economy.
Adoption, youth metrics, and engineering talent set up the Vietnamese digital assets ecosystem for growth.
- Vietnam ranked 4th globally in Chainalysis’s 2025 Global Crypto Adoption Index, behind only India, the United States, and Pakistan. APAC was the fastest-growing region in the world, with on-chain transaction value rising from $1.4 trillion to $2.36 trillion year-on-year. (2025 Global Crypto Adoption Index)
- An estimated 17 million Vietnamese (one in every six) own crypto. Annual transaction volumes are estimated to be USD230B.
- Adoption skews young. Around 70% of Vietnamese crypto owners are aged 18–34 (Triple-A 2022). Nearly half the country’s 100 million-plus population is under 44 (Disruption Banking).
Crypto in Vietnam is not only a speculative trade. Chainalysis describes it as everyday financial infrastructure for remittances, gaming, and savings.
On remittances specifically, Vietnam received roughly $16 billion in 2024 (World Bank data), one of the ten largest recipient markets in the world. These are large, recurring cross-border flows. Exactly the use case where stablecoins and on-chain rails compete on cost and speed. While there is no legislative momentum behind stablecoin payments in Vietnam today, the size of the remittance corridor mandates us to consider this a possibility in the future, and one where industrial leaders will be determined by present-day infrastructure choices.
Furthermore, the builder base in Vietnam is substantial. Sky Mavis, the studio behind Axie Infinity, was founded in Ho Chi Minh City and became Vietnam’s most valuable tech unicorn. It is not an isolated success: Kyber Network, TomoChain, Ronin, Viction, Coin98 and a deep bench of GameFi and infrastructure projects have come out of the same talent pool. At least ten Vietnamese blockchain startups have crossed $100 million valuations. The country combines a large pool of young engineers with costs well below Singapore or Silicon Valley.
Da Nang and Ho Chi Minh City, have been designated as sites for an international financial centre, and the local government has introduced incentives and sandbox plans aimed at attracting Web3 firms. This is a policy actively trying to onshore activity, not just tolerate it.
The shift from offshore to onshore
Until now, almost all of this activity has run through offshore platforms. The volumes are relatively substantial, but Vietnamese authorities have had little visibility, no AML oversight, and no investor protection. In 2025, Vietnam put forward a regulatory framework as a response to that gap.
Local institutions have engaged with the regulatory change. Five Vietnamese entities have cleared initial screening for exchange licences: VIXEX, SCEX (formerly LPEX), CAEX, TCEX, and Vietnam Digital Assets JSC.. Several of them are anchored by established banks and securities firms (Techcombank, VPBank Securities, and others appear in their shareholder structures).
The 2025 regulatory framework
In 2025 the government moved the digital assets market from, effectively, a grey zone to a controlled, onshore regulated industry. Two instruments matter:
- The Law on Digital Technology Industry (No. 71/2025/QH15), passed in June 2025 and effective 1 January 2026, recognises digital assets as property for the first time — they can be owned, transferred, and inherited under the Civil Code.
- Resolution No. 05/2025/NQ-CP, issued 9 September 2025, establishes a five-year pilot programme (2025–2030) for the issuance, trading, and supervision of crypto assets.
The rules are strict:
- VND-only. All offering, issuance, trading, and settlement must be in Vietnamese dong.
- Capital. Operators need a minimum charter capital of VND 10 trillion (~$380–400 million), higher than commercial bank requirements in many jurisdictions.
- Ownership. At least 65% of capital must come from institutional investors; foreign ownership is capped at 49%.
- Licensing. Only Vietnamese-incorporated entities licensed by the Ministry of Finance may operate. Oversight is split across the Ministry of Finance, the State Bank of Vietnam, and the Ministry of Public Security.
- Enforcement. The plan is to phase out offshore access. Once the first licence is issued, domestic investors trading on unlicensed venues could face penalties.
Current status
The legal foundation is in force, and applicants are now moving through a formal licensing process. Participating in the Vietnamese Pilot Programme is, in fact, part of the licensing process.
Under Decision No. 96, the Ministry of Finance (MoF) sets out 5 steps in acquiring a crypto exchange license issued by the State Securities Commission: document submission, document check, MoF’s approval to proceed (within 20 days of a complete file), up to 12 months for the applicant to file the remaining requirements, and final review and infrastructure inspection before a license is granted.
With the originally planned pilot launch of Q2 2026, we anticipate activity to ramp up in the coming months.
Where Fireblocks fits: custody tech stack for security and scale
We expect the first use case for our stack in Vietnam to be as a custody technology provider, whereby we enable licensed parties to securely manage digital assets.
Licensed custodians, typically part of digital assets exchanges, need to demonstrate they can safeguard clients’ assets to a defined standard before they can operate. The implementing rules cover client asset segregation, cybersecurity, and key management requirements.
Key features of the custody requirements:
- Definition: Custody is defined as “the receipt, storage, safekeeping, and transfer of crypto assets on behalf of clients, and assisting clients in exercising rights relating to custodied crypto assets”. In other words, a custodian should be able to control clients’ assets and should be needed by its clients to assist with their assets’ safekeeping.
- Data localisation: Sensitive data sets should be stored on infrastructure physically located in Vietnam and available for inspection.
- System security: Regulated intermediaries are expected to meet Level-4 information-system security certification.
- Compliance: AML, Travel Rule, and reporting controls ought to be implemented when custodied assets are being moved.
The Vietnamese regime is set up such that a lot of details are being worked through the Sandbox licensing process. However, at a principal level, the rules are consistent with the regulatory approach across ASEAN and beyond. Fireblocks supports regulated clients across all these jurisdictions, and it has been our experience that while the adjustment to domestic regimes can be costly, it does put all market participants and all their customers on a stronger and more secure footing.
Often, as domestic banks and exchanges obtain licenses to provide digital assets services, they partner with global infrastructure providers in order to access a depth of expertise, experience and investment in infrastructure that has already been tried and tested internationally.
Our offering
The pilot’s implementing rules directly cover custody, key management, cybersecurity, and data localisation, and an applicant must demonstrate compliance with them before going live.
Fireblocks provides infrastructure proven at institutional scale: trusted by 95+ banks and 2,400+ institutions, including BNY, ABN AMRO, and Revolut. Three main Fireblocks capabilities map to the pilot:
- Custody and key management – An institutional-grade stack for securing, transferring, and settling assets, with policy controls and governance. Operators can choose MPC or KeyLink HSM-based key management; both maintain all key material onshore and address the data-residency rule, while supporting the Level 4 information-system security certification the regime expects.
- Tokenization and transaction orchestration – The same foundation supports what an operator builds after custody: tokenized securities and deposits, trading and settlement, and AML and Travel Rule controls, without re-architecting.
- Network and connectivity – A neutral network of counterparties and liquidity venues where the operator sets its own trust perimeter and limits. Governance stays with the licensed entity.
A note worth making for the local market: MPC-based key management lets all key material remain onshore while removing single points of failure, helping a custodian meet both the data-residency and resilience expectations of the regime.
Outlook
Vietnam has the demand, the developers, and now the rules, a combination few markets can claim. The foundations are in place, the first serious licence applicants are moving through the process, and the momentum is unmistakable. For the institutions preparing to operate under the pilot, custody is where it begins, and getting it right opens the door to everything that follows. This is a market built to scale, and we are ready to help the operators leading it do exactly that. We are watching the progress of innovation in the market with real optimism.
This piece reflects publicly available information as of June 2026. Capital thresholds, VND/USD conversions, and the licensing timeline are moving — figures should be confirmed against the latest official sources before publication. Technical and legal descriptions should be reviewed by the relevant teams before this goes live.
