Web3 businesses operating in Vietnam must transition their bookkeeping to comply with the country’s newly active virtual asset pilot framework. Following the roll-out of Resolution 05/2025/NQ-CP and Circular 15/2026/TT-BTC, digital assets are no longer unaccounted for in local regulations. Instead, Vietnam now mandates that crypto trading and corporate holdings be processed under accounting principles similar to financial investments and securities. Whether you are an investor managing an enterprise treasury, a project issuing utility tokens, or a trading desk, aligning your sub-ledger operations with these exact updates is vital for tax compliance and audit survival.
1. Is cryptocurrency legal for businesses in Vietnam under the new pilot framework?
The legal status of crypto has shifted from an unregulated grey area into a strictly controlled, 5-year national pilot program enacted by the Government under Resolution 05/2025/NQ-CP (effective September 9, 2025). While cryptocurrency remains illegal to use as direct legal tender for purchasing everyday goods and services, the state has formally recognized “crypto assets” as a specialized sub-category of digital data assets.
Under this pilot market architecture:
Token Issuance: Vietnamese enterprises can legally issue crypto assets, provided they are backed by verified “real assets” and targeted primarily toward foreign investors.
Market Intermediation: Trading platform operators and crypto service providers (VASPs) must undergo rigid administrative screening. Per Decision 96/QĐ-BTC administered by the State Securities Commission (SSC), platforms must hold institutional-grade capital definitions to qualify for a formal operational license.
2. How do you classify crypto under Circular 15/2026/TT-BTC and VAS?
The historical practice of defaulting crypto into general inventory (VAS 02) or intangible assets (VAS 04) has been overridden by Circular 15/2026/TT-BTC (effective March 4, 2026). This circular provides concrete accounting baselines for market participants during the pilot phase.
| Corporate Role | Required Accounting Treatment (Circular 15/2026/TT-BTC) | Alignment with Core VAS Principles |
| Domestic Web3 Investors & Treasuries | Accounted for similarly to Financial Investments based on holding intent. | Tracked via investment ledgers; valued based on acquisition cost and real market benchmarks. |
| Licensed Trading Platforms (VASPs) | Accounted for similarly to Securities Proprietary Trading. | Immediate recognition of professional transaction revenues, service commissions, and operational overhead. |
| Token Issuers/ Projects | Accounted for based on the economic substance of the obligation generated by the asset. | Capital mobilization mechanisms must record corresponding liabilities or equity-like allocations on the balance sheet. |
Recording for Corporate Investors
If your business holds tokens for treasury management or portfolio growth, your ledger entries must mirror financial investment portfolios. You must establish a verified cost basis upon acquisition and monitor fair market adjustments systematically.
Recording for Token Issuers
If your corporate infrastructure issues native tokens to raise funds, you cannot simply look at it as unearned top-line revenue. You are required to analyze the underlying promises made to token holders (utility, access, governance) and record the incoming funds against those exact balance sheet obligations.
4. What are the updated tax implications for digital assets in Vietnam?
Because digital asset accounting is now aligned with financial investment behaviors, the General Department of Taxation evaluates transactions closely on their commercial substance.
- Corporate Income Tax (CIT): Web3 firms face the standard 20% CIT on net capital gains derived from trading, staking, or liquidity provisioning. Gains must be calculated using accurate fiat conversion rates at the exact hour of the transaction match.
- Foreign Investor Allocations: Because token sales under Resolution 05/2025/NQ-CP are targeted closely at non-residents, international inflows must navigate dedicated VND bank accounts opened at authorized foreign exchange banks in Vietnam to ensure clear anti-money laundering (AML) compliance.
- On-Chain Payroll Compliance: Despite the market pilots, paying onshore employees directly in tokens remains a high enforcement risk. Companies should establish their base payroll in VND, fulfilling standard local withholding obligations before using any approved international payment tracks.
5. What steps are required to build an auditable crypto accounting workflow?
To maintain compliance with the Ministry of Finance’s auditing requirements, your on-chain sub-ledger data must reconcile perfectly into your statutory localized accounting reports.
- Deploy a Compliant Web3 Sub-Ledger: Utilize enterprise-tier software (e.g., Bitwave or specialized digital asset sub-ledgers) to ingest raw transaction history via API directly from your multisig wallets and licensed VASP exchange accounts.
- Map to Financial Investment Portfolios: Configure your chart of accounts to process transactions under the financial investment and securities tracking logic mandated by Circular 15/2026/TT-BTC, moving away from legacy asset assumptions.
- Enforce Standardized Fiat Valuation: Bind your data pipeline to an authorized, institutional-grade price oracle or high-volume spot aggregator. Document this valuation methodology clearly inside your corporate accounting policy.
- Bridge into VAS Statutory Software: Reconcile all sub-ledger records on a monthly cycle, converting entries to VND before exporting the journal data into your primary VAS accounting system (such as MISA or Fast Enterprise) for official state filings.
The implementation of these new frameworks signals that Vietnam is aggressively building institutional space for digital assets. By executing your bookkeeping using the explicit guidelines of Circular 15/2026/TT-BTC, your Web3 business secures a significant first-mover advantage, remaining perfectly structured for future venture funding and regulatory clarity.
6. Ready to Align Your Web3 Business with Vietnam’s New Crypto Regulations?
Don’t let accounting complexities or compliance bottlenecks slow down your growth. Navigating Circular 15/2026/TT-BTC and Resolution 05/2025/NQ-CP requires specialized expertise to ensure your corporate infrastructure is completely audit-ready.
At Solvex Consulting, we help Web3 enterprises bridge the gap between on-chain data and statutory VAS frameworks seamlessly. Protect your treasury, streamline your operational workflows, and secure a bulletproof financial foundation.
Book Your Free Consultation Session Now . Let our experts build a tailored compliance roadmap for your business.
