Author: Liang Yu
Editor: Zhao Yidan
Vietnam's RWA path is a unique route that exchanges speed for scale and seeks order through regulation.
According to a report by Tencent News on November 5, 2025, Da Nang, a major city in central Vietnam, signed a memorandum of cooperation with Tether, the world's largest stablecoin issuer, to jointly promote blockchain governance and the tokenization of real-world assets (RWA), aiming to establish Da Nang as a regional fintech and digital asset innovation center. This move is the latest in a series of actions by Vietnam in the field of crypto assets. On September 9, the Vietnamese government issued Resolution No. 05/2025/NQ-CP, officially launching a five-year pilot program for the crypto asset market, providing a preliminary legal framework for digital assets such as RWA. As October approached, although the Ministry of Finance revealed in a routine press conference that no companies had formally submitted applications to participate in the market, relevant departments were already busy drafting detailed regulations to expedite the establishment of a compliant market.
Almost simultaneously, Vietnam and Hong Kong reached into the gearbox of real-world assets (RWA): Hanoi introduced legislation and licensing aimed at rapid ignition; Hong Kong, on the other hand, formalized the "Stablecoin Regulation," tying stablecoins to the backbone of financial infrastructure.
The two paths resemble two race cars at the starting line: one uses law as a brake to channel flows; the other uses regulation as a ruler to calibrate direction. Who is faster, who is steadier, determines not only the convenience of issuance channels and the depth of capital absorption but also the future ownership of "pricing power" and the weight of discourse.
1. Policy Gate: Transformation of Legal Framework from Ambiguity to Clarity
In early August 2025, the Vietnamese National Assembly passed the "Digital Technology Industry Law," which for the first time officially categorizes digital assets into "virtual assets" and "crypto assets," confirming that crypto assets are legal property rights under civil law.
This legislation is expected to take effect on January 1, 2026, marking a milestone step for the country in the crypto field. The new law aims to improve the relevant legal system, align with international regulatory standards, and help Vietnam exit the Financial Action Task Force (FATF) gray list as soon as possible, for which it mandates the implementation of anti-money laundering and counter-terrorism financing measures.
Just a month later, on September 9, 2025, Vietnamese Deputy Prime Minister Hu Duc Phuc issued Resolution No. 05/2025, officially launching the pilot program for crypto asset trading. This resolution took effect from the date of publication, with a pilot period of five years, continuing to operate until new regulations are introduced.
Vietnam's regulatory system presents a unique "multi-horse carriage" parallel structure. The State Bank, as the most conservative and cautious institution, focuses on maintaining financial stability and exploring central bank digital currency pilots; the Ministry of Finance leads the formulation of laws and regulations for digital assets and the improvement of the tax framework.
The Ministry of Justice promotes the clear definition of digital assets as a new asset class to resolve ownership disputes and uncertainties in legal contracts; while the Ministry of Public Security is responsible for combating financial crimes and implementing stricter "know your customer" and suspicious transaction reporting agreements for crypto platforms.
2. Market Landscape: Over $200 Billion in Capital Flow and Dual Challenges
Vietnam's digital asset market is exhibiting remarkable vitality and scale. In 2025, capital inflow into Vietnam's digital assets exceeded $220 billion, a 55% year-on-year increase, fully reflecting the enormous demand in cross-border remittances, savings, and digital service applications.
Vietnam's participation in the blockchain and digital currency sectors is noteworthy. According to data from Chainalysis cited by the Vietnam Blockchain Association, the inflow of capital into Vietnam's blockchain market exceeded $105 billion between 2023 and 2024, with profits nearing $1.2 billion in 2023.
The 2024 report from Triple A shows that over 20% of the Vietnamese population holds digital currencies. Vietnam ranks among the top three in Chainalysis' global cryptocurrency acceptance index, with a penetration rate 3 to 4 times the global average.
However, this rapid growth is accompanied by severe challenges. Despite Vietnam's introduction of a series of regulatory measures, early market irregularities and a lack of regulatory experience have led to some digital asset projects being exploited as tools for fraud.
From multi-level capital mobilization, virtual investment platforms to fraudulent "real estate tokenization" models, various scam cases have emerged. Statistics show that from the beginning of 2025 to now, nearly 1,500 online fraud cases have resulted in losses exceeding 16.6 trillion Vietnamese dong, with activities related to virtual and crypto currencies accounting for over 1,500 channels and groups.
This phenomenon not only reflects the growing pains of the early market development but also highlights the urgency of investor education.
3. Issuance Rules: RWA Market Access and Compliance Pathways
The Vietnamese government has implemented clear issuance rules and access conditions for the crypto asset market. According to Resolution No. 05, the issuing entity must be a limited liability company or joint-stock company legally established in Vietnam.
The issued crypto assets must be based on physical assets, reflecting the core concept of real-world asset tokenization, while the regulations explicitly exclude securities and the Vietnamese dong from this category.
Resolution 05 adopts a relatively restrictive regulatory approach to crypto assets, emphasizing control and compliance over liberalization to protect retail investors in the financial market. It does not completely deny the possibility of financial asset tokenization but delineates a clear testing ground for the market starting from physical assets.
There are mainly two pathways for crypto asset issuance. One is that crypto assets issued by Vietnamese entities must be supported by real underlying assets, which clarifies the compliance direction for RWA tokenization but temporarily excludes securities-type tokens.
The other is that crypto assets issued and provided by foreign entities before the effectiveness of Resolution 05 can be stored with licensed crypto asset service providers in Vietnam, and these crypto assets are not subject to the requirement of being supported by real-world assets.
This means that mainstream crypto assets like Bitcoin and Ethereum can enter the Vietnamese market through this channel operated by licensed service providers on major global platforms.
In terms of trading organization, crypto assets held by domestic investors and foreign investors can open accounts at licensed service institutions for custody and trading. Domestic investors must trade at the licensed institution for at least six months; otherwise, they will be subject to administrative penalties or criminal liability for violations.
4. Institutional Roles: Diverse Regulation and Sandbox Experiments
Vietnam has adopted a "loose regulation" pattern with multiple ministries responsible for digital asset regulation, forming a unique regulatory ecosystem.
In addition to government agencies, the Vietnam Blockchain Association serves as a bridge connecting the government and the industry, promoting the application of blockchain technology solutions in various aspects of economic life.
The regulatory sandbox mechanism has become an important means for Vietnam to explore the digital asset market. The country actively introduces regulatory sandbox mechanisms and pilot projects, such as trialing the use of the stablecoin USDT by international tourists in Da Nang to explore innovative applications under controlled risks.
The Vietnamese government has discussed establishing regional and international financial centers and plans to set up a fintech regulatory sandbox within them, allowing for testing of crypto asset and cryptocurrency business models.
The entry requirements for service providers are very strict. Service providing institutions must be Vietnamese enterprises and have registered relevant business scopes, with registered capital of no less than 100 trillion Vietnamese dong.
Among them, the institutional investment ratio must be no less than 65%, and at least two units must invest more than 35%. These units can include commercial banks, securities companies, fund management companies, insurance companies, or technology enterprises. The shareholding ratio of foreign investors cannot exceed 49%.
Applying institutions must have compliant headquarters and technical systems. The general manager should have more than 2 years of experience in finance, securities, banking, insurance, or fund management; the technical director must have more than 5 years of relevant experience. Enterprises must be equipped with at least 20 legally certified technical and securities professionals.
5. International Perspective: Comparative Advantages and Potential Risks of the Vietnamese Model
In the regulatory landscape of digital assets in Southeast Asia, different countries exhibit their own characteristics. Singapore, as a pioneer in this field, actively promotes and regulates tokenized securities through its "Fintech Regulatory Sandbox" managed by its Monetary Authority.
Singapore does not support the retail use of cryptocurrencies but actively promotes institutional stablecoin programs and studies the effectiveness of real-world asset tokenization through "Project Guardian."
Malaysia adopts a dual regulatory model, with the Securities Commission responsible for the regulation of digital payment tokens and digital asset exchanges, while the central bank oversees fiat-linked digital currencies.
The country has institutionalized, monitored, and made accountable the token issuance system through the IEO framework, leading to compliant cases such as fixed-income tokens from Integra Healthcare and tokens from the BidNow platform.
The most notable feature of the Vietnamese model is that exchanges have become the main entry point for compliant traffic and clearing. Obtaining a license and launching on designated platforms is equivalent to accessing local capital pools and policy dividends. The process is short and the pace is fast, especially suitable for the "first landing" of asset categories such as bonds, real estate, and supply chain receivables.
However, the cost of this model is a high dependence on platform operational capabilities and administrative approval timelines. Over-reliance on a few exchange platforms as clearing entry points, while convenient for regulation, may also bring risks of excessive market concentration and pose potential challenges in liquidity management and regulatory single points of failure.
Compared to Hong Kong, Vietnam is building a "fast track," prioritizing getting vehicles on the road and running; Hong Kong is establishing a complete set of "traffic rules," first calibrating vehicle conditions and fuel before allowing trial runs, ensuring that the road network can bear the load and vehicles can interconnect. Vietnam has an advantage in the "concentration" of entry, while Hong Kong has a strategic position in the "extensibility" of rules.
6. Economic Dynamics: Market Growth Driven by Multiple Factors
The deep-seated driving forces behind the development of Vietnam's crypto asset market stem from the interplay of multiple factors. First is the country's urgent pursuit of sustained economic growth; many financial analysts agree that the momentum for achieving high growth by 2026 cannot continue to rely solely on bank credit but must be supported by a robust capital market and strong domestic capital flows.
Data from the International Monetary Fund shows that Vietnam's credit-to-GDP ratio is nearing 150%—a very high level compared to other regional economies. This indicates that growth is primarily based on credit rather than productivity and long-term investment, posing risks to financial stability.
Secondly, there is an inherent demand for the expansion of the capital market. Experts warn that continued reliance on bank credit will increase systemic risks, put pressure on inflation, and undermine economic stability.
Currently, Vietnam's total private deposits amount to approximately 77 trillion Vietnamese dong—this is a massive domestic capital pool. If only 5% of this is invested in the stock market, the market could gain an additional $15 billion—far exceeding the $1-2 billion typically attracted from foreign exchange trading funds after market upgrades.
Thirdly, there are strategic considerations for attracting international capital and technology inflows. FTSE Russell's decision to upgrade Vietnam to emerging market status is not only a historical milestone but also a new starting point for the development of the country's capital market.
To maximize the benefits of this upgrade opportunity, the State Securities Commission and the Ministry of Finance have launched a comprehensive action plan focused on expanding supply by developing more market products and stimulating demand through attracting investment capital flows.
7. Challenge Risks: Analysis of Fraud Models and Regulatory Responses
Despite the promising outlook, Vietnam's RWA market still faces multiple challenges. A series of crypto asset projects have been exploited as tools for fraud, ranging from multi-level capital mobilization, virtual investment platforms to fraudulent "real estate tokenization" models.
Typical cases such as AnTex, Ifan, and Pincoin often attract investors with promises of high returns and multi-level marketing structures, leading to losses of hundreds of trillions of Vietnamese dong for tens of thousands of Vietnamese investors over the past five years.
These cases not only reflect the immaturity of the early market but also expose the challenges faced by the existing regulatory system in addressing cross-border, high-tech financial crimes. Data from the cybersecurity and high-tech crime prevention department indicates that from the beginning of 2025 to now, nearly 1,500 online fraud cases have resulted in losses exceeding 16.6 trillion Vietnamese dong.
One of the key issues is the lack of professionalism among investors. Su Chenhe, Deputy Director of the Market Development Department of the State Securities Commission, pointed out that the understanding capacity of Vietnamese investors remains low, while several digital asset fraud cases have recently occurred.
Funds can be transferred instantly, making it nearly impossible to recover or compensate in the event of fraud. This highlights the necessity of establishing investor suitability management and a professional investor system.
Dr. Can Van Luc, Chief Economist at BIDV, believes that if only foreign investors are allowed to participate, "Vietnam will lose its inherent potential." Therefore, he suggests allowing domestic professional investors to purchase digital assets, while simultaneously establishing corresponding risk assessment and investor protection mechanisms.
Additionally, the risks of money laundering and asset authenticity are also important concerns. Expert Nguyen Tri Hieu recommends that all digital asset transactions should be conducted through the banking system to control the flow of funds.
8. Future Outlook: The Evolution Path of RWA in Vietnam
In the short term, Vietnam's RWA market will undergo exploration and adjustment during the pilot phase. Su Chenhe emphasized that the initial stage will prioritize attracting international capital while allowing time to improve the legal framework and enhance public awareness.
This means that in the early stages of the pilot, market participants may face certain restrictions and adjustments, but it also provides a valuable window for establishing a robust market foundation.
In the medium to long term, Vietnam is expected to become an important player in the RWA field in Southeast Asia. Mr. Le Bao Nguyen, Deputy General Manager of SSI Digital, affirmed that Vietnam is a large market with purchasing power and a young, tech-savvy development team.
This is not only an advantage for Vietnam's participation but also an advantage for leading future digital financial platforms, whether in domestic or international markets.
The expansion of asset classes will be an important direction for future development. Currently, Resolution 05 mainly targets crypto assets supported by physical assets, while excluding securities and fiat currencies.
As the market matures and regulatory experience accumulates, there may be a gradual relaxation of the asset classes that can be tokenized in the future, including bonds, real estate, and broader asset categories such as supply chain receivables.
The Vietnamese government has discussed establishing regional and international financial centers and plans to set up a fintech regulatory sandbox within them, allowing for testing of crypto asset and cryptocurrency business models, with trading potentially starting as early as July 1, 2026.
These initiatives will further enhance Vietnam's position in the regional RWA market but will also require more efforts in regulatory coordination, risk prevention, and international cooperation.
With the "Digital Technology Industry Law" in Vietnam set to take effect in 2026 and the advancement of the five-year pilot program, this Southeast Asian country is building a high-speed channel for RWA characterized by national engineering. The continuous inflow of international capital—from the Giants Protocol supported by Singapore's sovereign wealth fund to Dunamu, the operator of Upbit in South Korea—is validating the attractiveness of this path.
The Vietnamese model provides a "gateway" for rapid market entry, allowing access to local capital pools and policy dividends through obtaining licenses and launching on designated platforms. However, this centralized path, while achieving efficiency, also brings a high dependence on platform operational capabilities and administrative approvals.
Whether the future RWA market in Vietnam can succeed hinges on finding a balance between promoting innovation and preventing risks, centralized regulation and market diversification.
Sources of some materials:
· "RWA Window in Asia: Vietnam's Policy Gate and Hong Kong's Standardization Race"
· "Focusing on Building a Compliant and Transparent Digital Asset Market"
· "Vietnam Launches Pilot Work for Crypto Asset Market"
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