In a landmark but deliberately restrained move, Vietnam has for the first time legally defined “cryptoassets” within its newly enacted Law on Digital Technology Industry. This marks a significant departure from the country’s previous regulatory vacuum, where the only official statement on cryptocurrencies was a 2014 press release from the State Bank of Vietnam (SBV) that described Bitcoin as “a kind of digital currency (virtual currency) which is neither issued by the government nor a financial institution.” That definition carried no legal weight, and for nearly a decade, businesses and investors operated in a grey zone where crypto was not explicitly banned as a payment method but was also not recognized in any statutory framework. The new law changes this landscape, but only partially—offering a high-level classification that deliberately avoids specifying the treatment of stablecoins, NFTs, or other fast-evolving digital assets, while simultaneously drawing a clear line between cryptoassets and regulated financial instruments like securities or digital fiat money. For the global blockchain community and enterprises eyeing Southeast Asia’s vibrant digital economy, understanding exactly what Vietnam has—and has not—codified is critical to navigating compliance, investment, and operational risk.
Vietnam Defines Cryptoassets Under the Law on Digital Technology Industry: A Long-Awaited Legal Foundation
The Law on Digital Technology Industry, passed by the National Assembly and recently brought into effect, introduces a statutory definition of “digital assets” that explicitly includes cryptoassets. This is the first time the term has been recognized in Vietnamese legislation, moving beyond the informal language used by the SBV in 2014. However, the law’s scope remains deliberately general. It does not classify cryptoassets into subcategories such as stablecoins, non-fungible tokens (NFTs), utility tokens, or security tokens. Instead, it adopts a three-part structure: digital assets are defined under the Civil Code as assets expressed in the form of digital data, created, issued, stored, transferred, and authenticated by digital technologies in an electronic environment. Within that broad category, the law enumerates three types: virtual assets in the electronic environment, cryptoassets, and other digital assets.
The inclusion of “other digital assets” is a notable regulatory hedge, intended to cover rapidly created digital assets that may not fall neatly into the first two categories. This open-ended clause signals that Vietnamese legislators are aware of the speed at which crypto innovation occurs and do not want to lock the framework into a rigid taxonomy that could become obsolete within months. Yet it also introduces legal uncertainty: what qualifies as “other digital assets” is left undefined, effectively delegating interpretive authority to future decrees, circulars, or court rulings. For now, the law provides a skeleton, not a full body of regulation.
Exclusion of Securities, Fiat Money, and Financial Assets
A critical feature of the new law is the explicit intention to exclude securities, digital forms of fiat money, and other financial assets as prescribed by law from the scope of cryptoassets or digital assets. This carve-out has profound implications. It means that any digital token that meets the legal definition of a security under Vietnam’s Securities Law will fall under the jurisdiction of the State Securities Commission (SSC), not under the Digital Technology Industry Law. Similarly, central bank digital currency (CBDC), should Vietnam ever issue one, would be treated as a form of fiat money and regulated separately by the SBV. The practical effect is that the cryptoasset definition in the new law applies primarily to assets that are not already regulated as financial instruments.
This exclusion helps prevent regulatory overlap and jurisdictional conflicts, but it also creates a potential gap: many crypto assets, including some stablecoins and tokenized securities, might technically qualify as both a cryptoasset under the new law and a security under existing laws. In such cases, the more stringent regulatory regime would likely prevail, but the law does not provide a clear hierarchy or conflict-resolution mechanism. Market participants will need to monitor subsequent implementing regulations closely to understand how dual-character assets will be treated.
What Is the Legal Status of Cryptocurrency as a Means of Payment in Vietnam?
Despite the new recognition of cryptoassets as a legal category, the government and state agencies do not recognize cryptocurrency as a legal means of payment. This position has remained consistent since the SBV’s 2014 statement and is reinforced by subsequent decrees and circulars. The issuance, provision, or use of cryptocurrency in Vietnam for payment purposes may subject individuals and entities to administrative penalties or criminal liabilities, depending on the specific violations in each case. The new law does not alter this prohibition. Instead, it creates a separate legal identity for cryptoassets as a form of property or asset, while keeping them out of the payments system.
This distinction is crucial for anyone operating in the Vietnamese market. You can legally own, trade, and perhaps even mine cryptoassets (pending further guidance), but you cannot accept them as payment for goods or services. Businesses that attempt to use Bitcoin, Ethereum, or any other cryptocurrency as a medium of exchange risk fines or worse. The law also implies that crypto exchanges and wallet providers must operate in a way that does not facilitate payment transactions, though the specific licensing and operational requirements have not yet been detailed. For now, the prohibition on payment use remains one of the most significant constraints on crypto adoption in Vietnam.
Comparison with the 2014 SBV Definition
Understanding the evolution from the 2014 SBV definition to the current law provides important context. In 2014, the SBV stated that Bitcoin was “not issued by the government nor a financial institution” and was “created and operated based on systems of computer connected to peer-to-peer internet network.” That definition was issued in a press release, not as part of an official regulation, so it had no binding legal force. It served more as an official acknowledgment of Bitcoin’s existence and a warning to the public about its risks. The 2014 statement notably used the terms “digital currency” and “virtual currency” interchangeably, and it did not distinguish between Bitcoin and other cryptocurrencies, nor did it address the broader concept of digital assets.
The new law replaces that ad-hoc language with a statutory framework that categorizes cryptoassets within a larger taxonomy of digital assets. However, it retains the core idea that cryptoassets are not government-issued and are not legal tender. The shift from a mere press release to a legislative act significantly raises the legal certainty for market participants—but only within the boundaries that the law establishes. The vagueness around “other digital assets” and the absence of detailed classifications for stablecoins and NFTs mean that much of the practical regulatory work will fall to secondary legislation and enforcement bodies.
How Does the Law on Digital Technology Industry Define Digital Assets?
For search engines and readers seeking a clear, snippet-friendly answer: Digital assets under the Law on Digital Technology Industry are defined as assets under the Civil Code, expressed in the form of digital data, created, issued, stored, transferred, and authenticated by digital technologies in an electronic environment. They are classified based on use purpose, technology, and other criteria. The law specifies that digital assets include virtual assets in the electronic environment, cryptoassets, and other digital assets. This definition is the first statutory recognition of digital assets in Vietnamese law, but it remains general and does not subdivide cryptoassets into specific types like stablecoins or NFTs.
Virtual Assets, Cryptoassets, and the Open-Ended “Other” Category
The law distinguishes “virtual assets in the electronic environment” from “cryptoassets” but does not provide separate definitions for each. This is a deliberate choice that leaves room for regulatory evolution. “Virtual assets” likely refers to digital items that are not necessarily cryptographic in nature—such as in-game currencies, loyalty points, or digital collectibles that exist on centralized platforms. “Cryptoassets” are presumably those that rely on distributed ledger technology, cryptography, and decentralized consensus. The catch-all “other digital assets” is designed to capture any digital representation of value that does not fit neatly into the first two buckets.
This tripartite structure mirrors approaches taken in jurisdictions like Japan and South Korea, where virtual currencies are defined broadly and then subclassified through subsequent regulations. However, Vietnam’s version is more skeletal. There is no mention of whether the law applies to utility tokens, governance tokens, or wrapped assets. The classification criteria (“use purpose, technology, and other criteria”) are mentioned but not elaborated, leaving room for administrative agencies to issue guidelines later. For companies building blockchain projects in Vietnam—or targeting Vietnamese users—this means that compliance cannot yet be fully assessed. The law sets a foundation, but the operational rules are still being written.
The Regulatory Gap: Stablecoins, NFTs, and Rapidly Evolving Digital Assets
One of the most discussed aspects of the new law is its silence on specific categories like stablecoins and NFTs. Stablecoins—cryptocurrencies pegged to a stable asset like the US dollar or gold—have become a major part of the crypto ecosystem, used for trading, remittances, and decentralized finance (DeFi). NFTs, or non-fungible tokens, represent ownership of unique digital items and have sparked an entire market for digital art, collectibles, and virtual real estate. Neither is explicitly mentioned in the law’s definition of cryptoassets, and neither is excluded. They fall into the open category of “cryptoassets” or possibly “other digital assets.”
This omission creates both opportunity and risk. On one hand, it allows the government to design targeted regulations for stablecoins and NFTs as they grow in prominence, rather than locking in a definition that might not fit future innovations. On the other hand, it leaves businesses and creators in a state of legal ambiguity. An NFT marketplace operating in Vietnam, for example, would need to determine whether its tokens are considered “virtual assets” or “cryptoassets” under the law, and whether any secondary market activity could be construed as an unregistered securities offering. The law’s exclusion of securities and financial assets means that if an NFT is deemed to represent an investment contract, it could fall outside the Digital Technology Industry Law entirely and into the purview of the SSC.
Practical Implications for Investors and Businesses
For retail investors and cryptocurrency traders in Vietnam, the new law offers some reassurance: cryptoassets are now legally recognized as property, meaning they can be owned, inherited, and potentially used as collateral in the future, subject to further regulations. However, the payment prohibition remains, so using crypto to buy a cup of coffee or pay rent remains illegal. Exchanges and wallet providers will likely be required to register with the government and comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations, but those details have not yet been published.
For blockchain startups looking to incorporate in Vietnam, the law provides a clearer foundation for token issuance—provided the tokens are not classified as securities. Projects issuing utility tokens that grant access to a platform or service may find a legal home under the cryptoasset definition, but they must avoid any features that could be interpreted as payment functionality. The law’s silence on decentralized finance (DeFi) protocols and smart contracts means that these remain largely unregulated for now, but that could change rapidly as authorities gain experience.
Foreign companies considering partnerships with Vietnamese firms or targeting Vietnamese users must also navigate the new definitions. If a product involves digital assets that the law calls “other digital assets,” the lack of clarity could lead to regulatory pushback. Until the government issues detailed guidance, the safest approach is to assume that any digital token that is not a clearly regulated security or fiat digital currency falls under the Digital Technology Industry Law’s general framework, with all the associated uncertainty that entails.
Administrative and Criminal Penalties for Violations
The law does not specify new penalties for crypto-related violations within its text, but it references existing legal regimes. Using cryptocurrency as a means of payment can lead to administrative fines ranging from tens of millions to hundreds of millions of Vietnamese dong (roughly $1,200 to $12,000 at current exchange rates), and in serious cases, criminal prosecution under articles related to illegal payment activities. The SBV has historically taken a strict stance, issuing warnings and conducting investigations into businesses that accept crypto payments. The new law reinforces this by embedding the prohibition in a statutory framework, making it easier for prosecutors to bring cases.
Additionally, the law introduces liability for entities that issue, provide, or intermediate cryptoassets in violation of regulations. While the specifics are not yet detailed, the general principle is that any activity not explicitly authorized could be deemed illegal. This is particularly relevant for initial coin offerings (ICOs), token sales, and crypto exchange operations. Many Vietnamese crypto exchanges have operated in a grey area, often without licenses, and the new law signals that a licensing regime will eventually be imposed. Operators should prepare for compliance obligations, including registration, reporting, and KYC/AML procedures.
What Comes After the Law: Secondary Legislation and Implementation
The Law on Digital Technology Industry is just the first layer of Vietnam’s crypto regulatory framework. As is common in Vietnamese legislative practice, the law provides broad principles, while detailed rules are issued through government decrees, prime ministerial decisions, and ministerial circulars. These secondary instruments will likely define categories like stablecoins and NFTs, set capital requirements for exchanges, specify tax treatment, and establish consumer protection measures. The timeline for these instruments is uncertain, but the government typically issues implementing decrees within six to twelve months of a law’s effective date.
Market participants should pay close attention to the Ministry of Information and Communications (MIC) and the Ministry of Finance (MOF), which are likely to lead the drafting process. The SBV will retain authority over payment-related issues, and the SSC will oversee any tokens deemed securities. Coordination among these agencies will be essential to avoid regulatory gaps or overlaps. Vietnam has a history of cautious but decisive regulation in technology sectors—the country banned ride-hailing app Uber but later licensed Grab, and it has implemented strict data localization requirements—so the crypto regulatory path is unlikely to be straightforward.
For now, the law represents a step forward in legal clarity, but it is a step taken with deliberate caution. The government is signaling that it wants to foster digital innovation while maintaining control over financial stability and consumer protection. The open-ended definition of “other digital assets” and the exclusion of financial instruments from the law’s scope give regulators flexibility to adapt as the market evolves. Whether this flexibility will encourage investment or stifle it depends on how quickly and clearly the implementing regulations are issued. In the interim, businesses and investors in Vietnam’s crypto space must operate with an acute awareness that the legal landscape is still being drawn—and that the lines may shift without warning.
