On January 21, 2026, the Vietnamese Ministry of Finance and the State Securities Commission jointly announced the launch of a pilot licensing system for cryptocurrency trading platforms, officially signaling the end of the gray cryptocurrency trading market that has been operating for eight years. The pilot program sets a minimum paid-in capital threshold of 100 trillion Vietnamese Dong (approximately 3.8 billion USD), creating a stark contrast with the current local trading ecosystem dominated by small matching stations and over-the-counter merchants. The market generally expects that only about 10 capable securities firms and banks will be able to enter. A market that has long been active with daily trading volumes, yet has operated on the fringes of regulation, is now forced to choose between "high compliance thresholds" and "low-cost gray operations." The real focus is not just on who will obtain the licenses, but how these stringent entry rules will reshape the power dynamics of Vietnam's cryptocurrency landscape.
Eight Years of Gray Trading Finally Sees Official Light
● Gray Ecosystem Profile: Over the past 8 years, local cryptocurrency trading in Vietnam has neither been legally recognized nor effectively banned, resulting in a gray ecosystem composed of retail speculators, large over-the-counter traders, cross-border arbitrageurs, and small matching platforms. Users participate through various means such as social media matchmaking, offline cash settlements, and registration on overseas platforms. In the local context, cryptocurrency assets are more often viewed as speculative tools and capital outflows rather than regulated financial products. This "tacit acceptance without endorsement" has been an invisible consensus in the industry.
● Policy Evaluation Turning Point: With the release of the pilot resolution, local Vietnamese media and analysis agencies commonly describe this action as "Vietnam's first clear legal status for cryptocurrency trading assets," emphasizing that its symbolic significance lies not only in licensing but also in a complete shift in regulatory attitude. Previously, whether exchanges were compliant depended on whether regulators "turned a blind eye," but now, having a license will directly determine whether a platform can operate publicly, connect to the banking system, and access advertising channels. The gray market is truly facing a binary choice of "being included in the system" or "being excluded."
● Shift in Regulatory Power: Prior to this, Vietnam's management of cryptocurrency trading mainly relied on central bank warnings and sporadic police crackdowns, focusing more on preventing fraud, illegal fundraising, and cross-border money laundering. This time, the State Securities Commission will formally control the issuance of licenses, indicating a shift in regulatory perspective from "public safety and payment issues" to "securities and capital market order." Cryptocurrency platforms will be brought under the same regulatory framework as securities firms and brokers. The focus of regulatory power is shifting from law enforcement to capital market oversight, treating cryptocurrency trading as a financial infrastructure that can be institutionalized and sustainably managed.
100 Trillion Threshold: Licenses Only for…
● High Capital Requirements: The pilot program's minimum paid-in capital standard of 100 trillion Vietnamese Dong (approximately 3.8 billion USD) is equivalent to the scale of medium to large securities firms or banks within the Vietnamese financial system. For local cryptocurrency platforms that previously only required a few servers, a matching engine, and several customer service teams to operate, this threshold represents an almost "ceiling-level" capital requirement, clearly signaling that "to enter, one must possess the capital strength and risk resistance of traditional financial institutions."
● Intent to Eliminate Long Tails: Some analysts point out that this capital threshold "could eliminate 90% of existing gray platforms," leaving only a very small number of well-capitalized players capable of competing with banks and large brokers. For regulators, this design almost directly compresses the long tail—those small platforms that attract retail investors with high leverage and thin risk control, and are easily involved in fraud and exit events, will be cut off at the institutional door. The goal of the new rules is not to give all existing participants a "clean slate," but to directly reconstruct the list of participants through high thresholds.
● Implicit Comprehensive Threshold: 100 trillion Dong is not just a capital figure; it also serves as a layer of "implicit screening" for technology, risk control, and compliance. Platforms that can present such a scale of paid-in capital typically already have mature IT infrastructure, compliance teams, and internal control systems, capable of meeting the series of hard requirements for cybersecurity, governance structure, and risk management outlined in the pilot program. Conversely, those relying on outsourced technology, lacking self-built security systems, and whose risk control is primarily based on "manual review + experience judgment," will find it difficult to sustain ongoing investment and scrutiny even if they barely meet the funding requirements.
Brokers and Banks Compete for Position: Who Can Absorb…
● Traditional Financial Entry Queue: Under this high threshold, the market generally expects the first batch of license holders to be concentrated among about 10 established securities firms and banks, with leading brokers like SSI Securities seen as the most likely traditional financial representatives to secure positions first. These institutions already possess proprietary trading systems, investment research teams, and online brokerage channels, making the expansion into cryptocurrency assets more of an "additional product line" rather than building a new company from scratch, giving them a clear advantage in terms of time and cost.
● Inherent Compliance and Risk Control Advantages: Compared to gray platforms, these licensed financial institutions have long been subject to multiple regulatory requirements such as anti-money laundering, anti-terrorist financing, and customer fund segregation, and have established mature KYC processes, transaction monitoring systems, and audit mechanisms. When cryptocurrency trading is included under the same regulatory framework, they can directly reuse their existing compliance and risk control systems, managing cryptocurrency assets as a new asset class rather than a "high-risk business" that requires starting from scratch. This institutional inertia makes it easier for them to pass license evaluations and subsequent reviews.
● Regulatory Arbitrage and Trading Reflow: Drawing on experiences from some mature overseas markets, once a regulated cryptocurrency trading platform emerges locally, some trading volumes that originally flowed to overseas exchanges may return due to the convenience of fiat currency deposits and withdrawals, tax compliance needs, and legal protections. This creates potential regulatory arbitrage space for Vietnam: platforms holding local licenses can legally access the banking system and institutional funds, accommodating those funds that were previously hesitant to engage directly with overseas platforms due to compliance risks, thus capturing market increments in the "safety and compliance premium," while gray platforms are further squeezed into high-risk margins.
Licenses in the Hands of the Securities Commission: Safety Clauses…
● Dominance of Securities Perspective: With the State Securities Commission uniformly controlling cryptocurrency platform licenses, it means that regulators will view cryptocurrency business through the lens of "exchanges + brokers." Platforms will no longer be simply seen as internet applications but will be classified as part of capital market infrastructure, required to comply with a complete set of securities rules such as information disclosure, customer asset segregation, and internal trading restrictions. This securities perspective determines that regulatory focus will center on market fairness, systemic risk, and investor protection, rather than just monitoring individual violations.
● Technical Red Lines for Safety and Governance: According to the information framework disclosed in the pilot program, future licensed platforms will need to meet a series of cybersecurity and governance standards, including but not limited to system redundancy design, data encryption storage, disaster recovery plans, and clear corporate governance structures. For the technology stack, this means that self-developed matching engines, risk control engines, and security audit mechanisms will shift from "optional enhancements" to "necessary conditions for entry." Small platforms that previously relied on third-party template systems and lacked regular security testing will find it difficult to survive in this round of selection.
● Continuous Review Reshaping Boundaries: Licenses are not a "one-time" permit but are dynamically linked to continuous compliance reviews. Regulatory agencies have the authority to adjust license statuses based on operational conditions, require rectifications, and even revoke licenses in cases of serious violations. This expectation itself will reshape the operational boundaries of platforms. When designing product leverage, listing standards, and marketing strategies, platforms must leave space for regulatory red lines, abandoning past reliance on extreme leverage, high-yield inducements, and aggressive marketing to attract new users. The entire market order will gradually tighten under the dual constraints of "licenses + continuous reviews."
Gray Platforms Exit or Turn to Compliance
● Three Life-and-Death Routes: Under the judgment that "90% of existing gray platforms may be eliminated," many small and medium platforms face three choices: shutdown, go overseas, or be acquired and outsource technology. For those with the weakest financial strength, direct shutdown and liquidation of user assets may be the only realistic option; some teams with certain technical capabilities and overseas connections may attempt to relocate their servers and entities to more lenient jurisdictions to continue operations; while those still optimistic about the local market but unable to independently apply for licenses may choose to package and sell their matching systems and user pools or operate under licensed institutions as technology service providers.
● Cost Impact of Compliance Transformation: For small and medium platforms, the cost of transitioning from "gray operations" to "compliant financial institutions" involves not only one-time capital supplementation but also long-term audit, compliance, risk control, and security investments. Directly applying for licenses is almost unrealistic; "affiliating with licenses," "white-label technology output," and "becoming a traffic channel for licensed platforms" will become the main gray cooperation paths they can see. However, this cooperation also means significantly compressed profit margins and weakened business autonomy, as business models that once relied on flexible listing and high leverage for exorbitant profits will be forced to give way to a "infrastructure-type" role with low risk and low marginal returns.
● User Migration Psychology and Liquidity Pain: On the user side, migrating from anonymous high-leverage gray platforms to KYC-compliant, leverage-restricted, and traceable fund paths compliant platforms involves not only time and procedural costs but also a psychological gap. Some high-risk preference users may turn to uncontrolled overseas platforms or remain in the residual gray market, leading to short-term pressure on the trading depth and liquidity of locally regulated platforms. It will only be when institutional funds and conservative retail investors gradually enter, and the user structure is reconfigured, that the market is expected to become active again at a more stable but no longer frenzied pace.
From Pilot to Full Release: The Vietnamese Way…
Vietnam's pilot licensing marks a key turning point in regulation, shifting from past "tacit acceptance of gray operations and post-fact enforcement" to "strict pre-control and compliance for entry," which is crucial for the development of the local cryptocurrency market. Winners will be highly concentrated among traditional financial institutions with strong capital, mature risk control, and compliance capabilities, while small and medium gray platforms that have long relied on regulatory loopholes and model arbitrage will be forced to make difficult choices between shutdown, going overseas, or seeking compliance. In the future, the smoothness of the approval process, how supporting details are implemented, and how penalties for violations are calibrated will largely determine whether Vietnam can truly grow into a regional cryptocurrency trading hub or merely form a limited-scale, highly closed local compliant market. The more open question is: in balancing high thresholds for safety and leaving room for innovative vitality, which end will Vietnamese regulation lean towards this time, and whether it will be willing to leave enough trial-and-error space for new technologies and models in the future.
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