Vietnam's Digital Asset Play: What Decree 323's Priority Sectors Signal

The detail that matters#

Most international financial centres launch with generalities. Their founding instruments speak of "financial services," "capital markets," and "innovation" in terms broad enough to accommodate whatever the market delivers. The specifics come later, in subsidiary regulations and licensing frameworks, once the political dust has settled.

Vietnam has done something different.

Decree No. 323/2025/ND-CP, the instrument that formally establishes the Vietnam International Financial Centre as a unified entity across Ho Chi Minh City and Da Nang, includes an annex — the List of Priority Sectors, Products, and Services for Development in the IFC. Section 4 of that annex is where things get interesting.

It doesn't speak vaguely about "financial technology." It catalogues, with unusual precision, the specific activities Vietnam intends the VIFC to accommodate:

• Digital assets and digital asset infrastructure
• Decentralised finance (DeFi)
• Asset tokenisation, including real-world asset (RWA) tokenisation
• Stablecoins
• Web3-based applications
• Non-fungible tokens (NFTs) — further detailed in Decree 330, which permits NFTs structured as cultural and artistic products to be traded on commodity exchanges
• Regulatory technology (regtech)

This is not buried in a footnote. It is in the founding document's priority catalogue — the list that determines which sectors receive preferential licensing, tax treatment, and sandbox access.

For anyone tracking how Asian financial centres position themselves on digital assets, this level of specificity in an establishment decree is, to put it plainly, unprecedented.

Why specificity matters more than permissiveness#

It is tempting to read this as Vietnam simply being "crypto-friendly." That reading misses the point.

Plenty of jurisdictions are permissive toward digital assets in practice. What Vietnam has done is different: it has embedded digital asset activities into the structural architecture of its financial centre from day one. The distinction matters for three reasons.

First, it constrains future regulators. A priority sector designation is not a policy speech or a ministerial statement of intent. It is gazetted in a decree that implements a National Assembly resolution. Rolling it back requires formal legal action, not a change of mood. The bureaucratic cost of removing DeFi from the priority list is materially higher than the cost of never having listed it.

Second, it shapes the incentive stack. Under Decree 324, which governs financial policies within the VIFC, members operating in priority sectors gain access to the IFC's most favourable terms: a 10% corporate income tax rate for 30 years, sandbox participation with liability shields during testing, and streamlined licensing through the IFC Executive Authorities rather than national-level regulators. These benefits are tied directly to the priority sector list. If your activity is on the list, you are in the fast lane. If not, you operate under the standard IFC regime — still attractive, but materially less so.

Third, it signals to the market infrastructure layer. Exchanges, custodians, clearing houses, and technology providers make multi-year investment decisions based on regulatory architecture, not conference rhetoric. When a government names "digital asset infrastructure" and "multi-asset depository, clearing, and settlement centres" as priority activities in the same decree, it is telling infrastructure builders: we have designed the plumbing to accommodate you.

How this compares to peer IFCs#

No two international financial centres are directly comparable, but the contrast in founding-document specificity is instructive.

The Dubai International Financial Centre (DIFC) was established in 2004 with broadly defined objectives around financial services. Its digital asset framework emerged much later, through the DFSA's Investment Token regime (2021) and the subsequent crypto token framework. The DIFC's digital asset positioning is now sophisticated — but it was layered on after the centre's architecture was set.

The Astana International Financial Centre (AIFC) in Kazakhstan took a more proactive approach, creating the AFSA's fintech sandbox relatively early in its development cycle. But even the AIFC's founding instruments did not name specific digital asset categories. The framework evolved through subsidiary rules.

GIFT City in Gujarat, India, has a growing fintech sandbox under IFSCA, but its founding architecture was oriented primarily toward traditional financial services — banking, insurance, capital markets. Digital assets remain a work in progress, with IFSCA consulting on frameworks.

Vietnam's approach is qualitatively different. By naming DeFi, tokenisation, stablecoins, and Web3 in the founding decree's priority annex, the VIFC has done at establishment what its peers did — or are still doing — years into operation.

This is partly a function of timing. Vietnam is a late mover among Asian IFCs, and late movers have the advantage of seeing what the market actually wants. But it is also a deliberate policy choice. The Vietnamese government has been signalling its digital asset intentions through multiple parallel channels:

• Resolution No. 05/2025/NQ-CP established a national pilot crypto asset market in September 2025
• The Ministry of Finance began accepting licence applications for crypto trading platforms in January 2026
• Da Nang approved its first fintech sandbox trial — for Basal Pay, a digital asset conversion project — making it the first such approval in Vietnam
• Binance signed an MOU with the Ho Chi Minh City Department of Finance in November 2025 to support VIFC development

The Decree 323 annex is the capstone of this sequence, not the starting point. It formalises in law what has been building in policy for over a year.

The sandbox architecture: where the action will be#

For digital asset firms evaluating the VIFC, the most operationally significant feature is the sandbox mechanism. Article 24 of Resolution 222 established the legal basis for a fintech sandbox within the IFC, and Decree 324 develops the framework further.

The sandbox design has several features worth noting:

• Liability shields: members participating in sandbox programmes are exempted from liability for damage to the state during the testing period — a provision that materially reduces the risk of early-stage deployment
• Five-year licensing window: the IFC Executive Authorities can issue licences for unregulated technologies, products, services, and business models for a maximum of five years
• Local authority, not national bureaucracy: sandbox approvals are handled by the VIFC-HCMC and VIFC-DN Executive Authorities, not by the State Bank of Vietnam or the Ministry of Finance directly — compressing decision-making timelines
• Dual-track opportunity: Da Nang is explicitly oriented toward being the testing ground for new financial models, while Ho Chi Minh City serves as the scaling environment

The criteria, conditions, and detailed procedures for sandbox participation are to be further specified by the IFC Executive Council — the central strategic body chaired by the Prime Minister, with the Ministry of Finance as the standing agency. These implementing details are the next critical milestone to watch.

The NFT and commodity exchange angle#

One detail that has received less attention than it deserves: Decree 330, which governs commodity exchanges within the VIFC, clarifies that goods permitted to be traded under Article 13 of Resolution 222 include not only traditional commodities but also certain digital assets — specifically, cultural and artistic products structured as NFTs.

This is a narrow category, deliberately. Vietnam is not opening the floodgates to all NFT trading on commodity exchanges. But it is creating a legally defined pathway for a specific class of digital assets to access exchange infrastructure from day one. For firms building in the intersection of digital assets and commodity markets — carbon credits, real-world asset tokens, cultural NFTs — this is a concrete entry point, not a theoretical one.

Read together with the priority sector designation for "commodity markets, commodity and commodity derivatives exchanges linked to domestic and international physical commodity markets," the architecture for tokenised commodity trading within the VIFC is already sketched out at the decree level.

The ex post supervision shift#

The regulatory philosophy underpinning the VIFC's digital asset framework is worth understanding. Circular 72/2025/TT-NHNN, issued by the State Bank of Vietnam on December 31, 2025, implements Decree 329 and marks a fundamental shift from ex ante licensing to ex post supervision for IFC members.

In practical terms, this means IFC member enterprises — including digital asset firms operating within the VIFC — will not need to obtain prior approval for every transaction, currency conversion, or capital movement. Instead, they operate under declaration and reporting obligations, with supervisory scrutiny applied after the fact.

For digital asset businesses accustomed to navigating Vietnam's historically cautious regulatory posture toward crypto and blockchain, this is a significant change in operating environment. The VIFC is designed to be a space where the default is "operate first, report accurately" rather than "apply first, wait, then operate."

The corollary, of course, is heightened self-compliance responsibility. The ex post model demands robust internal controls, accurate declaration, and timely reporting. Firms that treat lighter-touch supervision as an invitation to cut corners will find the IFC Supervision Authority — an independent enforcement body with inspection and examination powers — less accommodating than the entry regime might suggest.

What to watch next#

The Decree 323 priority sector annex is the architectural statement. The operational details are still being built. Three developments will determine whether the VIFC's digital asset ambitions translate into a functioning market:

1. IFC Executive Council implementing rules for the sandbox. The sandbox mechanism exists in law, but the specific criteria for admission, testing boundaries, consumer safeguards, and exit procedures are to be specified by the Executive Council. Until these are published, firms cannot formally apply. The timeline matters: Da Nang's Basal Pay approval suggests the Da Nang Executive Authority is moving faster than the formal framework might imply.

2. Operating rulebooks for digital asset activities. Decrees create legal authority. But the day-to-day rules — trading rules, surveillance obligations, participant requirements, reporting formats — come from operating rulebooks issued by IFC authorities and venue operators. These are what make a market actually function.

3. Interaction with the national crypto pilot. Vietnam is now running two parallel digital asset frameworks: the national pilot under Resolution 05 (with MOF licensing via the State Securities Commission) and the VIFC sandbox under Resolution 222 (with IFC Executive Authority licensing). How these interact — whether IFC-licensed platforms can serve national markets, whether national pilot licensees gain IFC access — will shape the competitive landscape for digital asset operators.

The bottom line#

Vietnam has placed a specific, legally binding bet on digital assets as a pillar of its international financial centre. The VIFC's founding decree names DeFi, tokenisation, stablecoins, Web3, and NFTs not as aspirations but as priority activities entitled to the centre's most favourable regulatory and fiscal treatment.

This is not a tentative signal. It is an architectural choice, embedded in law, backed by an integrated regulatory system of eight implementing decrees, and supported by a governance structure that reaches to the Prime Minister's office.

For digital asset firms assessing their next jurisdiction, the question is no longer whether Vietnam is serious about this space. It is whether the implementing machinery — the sandbox rules, the operating rulebooks, the licensing procedures — can be stood up fast enough to capture the moment.

"The usual IFC playbook is to start conservative and liberalise later. Vietnam has inverted the sequence — put the ambitious framework in the founding documents, then use the sandbox to manage risk during implementation. It's a bet that specificity attracts capital faster than caution."

The firms paying closest attention are not waiting for every detail to be finalised. They are engaging now — with the Executive Authorities, with the Da Nang sandbox, with the emerging ecosystem of founding and strategic members. In a market where first-mover positioning matters, the Decree 323 annex is the starting gun.