On 16 July 2026, the Government of Vietnam issued Decree No. 284/2026/ND-CP, on administrative penalties for violations concerning crypto-assets and the crypto-asset market. The decree was signed on behalf of the Government by Deputy Prime Minister Nguyen Van Thang, and published in Official Gazette No. 449 on 28 July 2026. It takes effect on 1 September 2026 and applies for the country's crypto-asset market pilot.
The Government created that pilot a year earlier with Resolution No. 05/2025/NQ-CP, issued on 9 September 2025, to run for five years and authorise a controlled, licensed crypto-asset market. The Ministry of Finance began accepting licence applications on 20 January 2026 under Decision No. 96/QD-BTC. Decree 284 provides the enforcement layer on top of that framework: the fines that apply while the licensed market is still being built out.
What the penalties cover
The decree sets its fines for organisations, and an individual who commits the same violation pays half, under Article 4. The ceiling is 200 million dong for an organisation and 100 million dong for an individual. Merely owning crypto is not penalised. Fines apply to trading, providing services, issuing tokens, moving funds, mishandling account data, and anti-money-laundering breaches. The figures below are the decree's stated organisation rates unless noted, and the US dollar approximations are indicative.
On the trading side:
- 30 to 50 million dong for a domestic investor trading through a venue not licensed by the Ministry of Finance, under Article 9(1). Halved for an individual, that is 15 to 25 million dong, roughly US$575 to US$960. Under Article 7(2) of Resolution 05, a domestic investor faces penalties for trading through an unlicensed venue only from six months after the first service provider is licensed, so the Article 9(1) fine cannot apply in practice until that clock starts.
- 70 to 100 million dong for a domestic investor trading crypto-assets offered or issued to foreign investors under Article 9(2), again halved for an individual.
- 50 to 70 million dong for a service provider that fails to verify an investor's identity, the decree's know-your-customer duty, under Article 8(3).
- 150 to 200 million dong for the unauthorised collection, storage or disclosure of crypto-account data, under Article 11(1).
Operating a trading venue, or advertising one, without a licence draws 180 to 200 million dong, under Article 7(4). On the issuance side, an issuer that breaches foreign-ownership rules on the underlying asset faces 70 to 100 million dong (Article 6(1)), inaccurate or incomplete disclosure 100 to 150 million dong (Article 6(2)), and improper offering, such as selling to ineligible investors or failing to publish a prospectus, 150 to 200 million dong (Article 6(3)).
The licence that is still being built
The penalties arrive while the compliant market they point to is only months into forming. Applications opened on 20 January 2026, and the bar to clear is high. Under the pilot's terms, a licensed operator must have paid-in charter capital of at least 10 trillion dong, roughly US$380 million, contributed in Vietnamese dong.
The applicant must be a Vietnamese enterprise: at least 65 per cent of its charter capital must come from institutional shareholders, and, within that, more than 35 per cent must come from at least two qualifying institutions, such as commercial banks, securities firms, fund managers, insurers or technology enterprises. Total foreign ownership is capped at 49 per cent.
That structure narrows the field to well-capitalised, domestically backed consortia, which means compliant venues are likely to be scarce for some time even as the penalty regime goes live.
Vietnam is not alone in pairing a new statutory market with a hard entry test: Taiwan has built a statutory crypto licensing regime under its Virtual Asset Service Act, and Singapore's licensing route has been marked by a low approval rate. The regional pattern is a deliberately steep on-ramp.
A separate track in Da Nang
Alongside the national pilot, the Government is standing up a Vietnam International Financial Centre in Da Nang, known as VIFC-DN, which is running its own controlled experiments in new financial models, including digital-asset trading. Under the international financial centre framework, members have wider foreign-currency latitude than the national track allows, creating a more flexible environment for the models being tested there. It is a distinct route with its own rules, not a way around the decree.
What it means for firms operating in Vietnam
For payments providers, digital-asset firms and the fintech teams building into Vietnam, the practical message is that enforcement now has a fixed price and a fixed date. Compliance, legal and product teams should act before 1 September, not after.
- Map the exposure. Operating or advertising a venue not licensed by the Ministry of Finance is fined from 1 September, and issuance and service-provider breaches carry fines from the same date. The Article 9 fine on a domestic investor who merely trades through an unlicensed venue is different: it applies only from six months after the first licensed provider. Separate licensed-market activity from other services, and identify where users are routed to unlicensed venues.
- Plan for scarce on-ramps. The 10 trillion dong, Vietnamese-majority bar means few operators will qualify quickly. Firms that rely on a compliant domestic venue should build in a window where one may not exist.
- Tighten identity and data controls. The decree fines a provider's identity-verification failures at 50 to 70 million dong (Article 8(3)) and unauthorised handling of account data at 150 to 200 million dong (Article 11(1)). Investor-verification and data-handling processes should now be reviewed against those duties.
- Weigh the Da Nang route. Firms exploring digital-asset models may find more room inside the VIFC-DN sandbox than under the national pilot, and should engage that channel deliberately rather than defaulting to it.
Vietnam's sequence, penalties first and licensed venues still forming, tells regulated firms that its authorities will not wait for the market to mature before enforcing its edges. The same discipline is visible elsewhere: the European Union's MiCA grandfathering deadline left many crypto firms operating without authorisation once the clock ran out, and Taiwan has set a phased timetable for its crypto travel rule. Until the first licences are granted under the pilot, the compliant path in Vietnam is narrow. From 1 September, the decree's penalties are fixed in law, though the fine on a domestic investor for merely trading through an unlicensed venue only begins to run six months after the first provider is licensed.
Read the full text of Decree No. 284/2026/ND-CP in the Official Gazette, and Resolution No. 05/2025/NQ-CP on the Government legal portal.
