Decree 330 Explained: Commodity Exchanges, Clearing, and Settlement Within the VIFC

What Decree 330 does#

Decree No. 330/2025/ND-CP, issued on 18 December 2025, is one of the eight implementing decrees under Resolution 222. While most of the other decrees address the conditions for operating within the VIFC — banking rules, tax treatment, immigration, land use — Decree 330 addresses something different: what can be traded and how.

The decree establishes the legal basis for commodity exchanges within the VIFC and sets out rules governing their establishment, the products they can list, the participants they can admit, and the clearing and settlement infrastructure they must maintain.

For anyone coming from a derivatives or commodity trading background, Decree 330 is where the VIFC starts to look like a market rather than a regulatory zone.

What counts as a "commodity" under this decree#

This is where Decree 330 gets interesting. The scope of goods permitted to be traded via commodity exchanges under Article 13 of Resolution 222 goes well beyond what most people would associate with the word "commodity."

Traditional commodities#

The decree covers the asset classes you would expect: agricultural products, energy, metals, and other physical commodities that are traded on exchanges globally. Vietnam is a major producer and exporter of coffee, rice, rubber, pepper, and cashew nuts — all of which could underpin futures and options contracts on a VIFC commodity exchange.

Carbon credits#

Resolution 222 explicitly authorises the creation of trading platforms for carbon credits, and Decree 330 provides the exchange framework for these instruments. Vietnam has committed to net-zero emissions by 2050 and is developing a domestic carbon market. A VIFC-based carbon exchange could serve both the domestic compliance market and voluntary carbon credit trading across the region.

Green financial products#

Broader than carbon alone, the decree permits trading in green financial products — a category that could encompass green bonds, sustainability-linked derivatives, renewable energy certificates, and ESG-rated instruments. The VIFC's priority sector list under Decree 323 includes green finance and ESG as a dedicated category, and Decree 330 provides the exchange mechanism.

Cultural and artistic products structured as NFTs#

Perhaps the most distinctive provision: Decree 330 clarifies that the goods permitted for exchange trading include cultural and artistic products structured as non-fungible tokens (NFTs). This is not buried in a footnote — it is an explicit policy choice that positions the VIFC as a venue for regulated NFT trading at a time when most jurisdictions are still debating whether and how to regulate these instruments.

The scope is deliberately limited to cultural and artistic NFTs rather than all digital assets. Broader digital asset trading — including tokenised securities, stablecoins, and DeFi products — falls under the fintech and innovation priority sector governed by Decree 324's sandbox mechanism rather than the commodity exchange framework.

Rare metals#

The decree also covers rare metals trading. Vietnam has significant rare earth deposits and is a growing player in the global rare earth supply chain. An exchange-traded market for rare metals could serve both price discovery and risk management functions for miners, processors, and industrial buyers.

Derivative instruments#

Decree 330 permits commodity exchanges within the VIFC to list and trade a range of derivative instruments:

• Futures contracts — standardised agreements to buy or sell a commodity at a specified price on a future date
• Options contracts — the right, but not the obligation, to buy or sell at a specified price
• Other derivatives — a catch-all category that provides flexibility for the exchange to develop new product types as the market evolves

This is a broad mandate. Vietnam's existing domestic commodity exchange (MXV) is relatively nascent compared to regional peers such as SGX or the Dalian Commodity Exchange. The VIFC framework is designed to leapfrog that starting position by allowing exchanges to launch with a full derivatives product suite from day one.

Who can operate a commodity exchange#

Decree 330 sets out the requirements for establishing a commodity exchange within the VIFC. The exchange operator is a legal entity — either newly formed within the VIFC or an existing entity that obtains VIFC membership and the relevant licence.

Key requirements#

While the decree provides the framework, the specific capital requirements, technical infrastructure standards, and governance requirements for exchange operators are expected to be further detailed by the IFC Management Authority. Based on the decree's provisions and comparable IFC frameworks, exchange operators will need to demonstrate:

• Adequate capitalisation — sufficient to cover operational risk, default fund contributions, and technology investment
• Technical infrastructure — trading systems, market surveillance capabilities, data dissemination, and cybersecurity
• Governance and compliance — fit-and-proper requirements for directors and senior management, conflicts-of-interest policies, and compliance frameworks
• Risk management — pre-trade and post-trade risk controls, position limits, and margin methodologies

The clearing and settlement centre#

Decree 330 does not treat clearing as an afterthought. The decree provides the legal basis for establishing clearing and settlement centres within the VIFC — central counterparty (CCP) infrastructure that stands between buyers and sellers, guaranteeing trade completion and managing counterparty risk.

This is a critical piece of market infrastructure. Without a clearing house, an exchange is essentially a matchmaking platform. With one, it becomes a venue where counterparty risk is mutualised and managed, enabling participants to trade with confidence that settlement will occur.

The VIFC's priority sector list under Decree 323 explicitly includes the construction and operation of multi-asset depository, clearing, and settlement centres as a priority business line. VIFC-HCMC has publicly stated its intention to invest in a centralised hybrid clearing system, with ambitions to use blockchain as the reconciliation and settlement layer to build a T+0 clearing system.

How this connects to the broader VIFC framework#

Decree 330 does not operate in isolation. A commodity exchange within the VIFC sits at the intersection of several regulatory instruments:

Banking and FX (Decree 329 + Circular 72)#

Exchange participants — whether trading firms, brokers, or clearing members — will need access to foreign currency accounts at IFC member banks. The ability to transact in foreign currency under Decree 329 is what makes a VIFC commodity exchange viable for international participants. A derivatives exchange where margin must be posted and settlement conducted in VND through a prior-approval process would not attract global trading firms. The liberalised FX regime removes that barrier.

Financial policies and membership (Decree 324)#

Exchange operators, clearing houses, and trading participants must be VIFC members under Decree 324's registration or recognition framework. The tax incentives — 10% corporate income tax for 30 years in prioritised sectors — apply to exchange and clearing house operators, making the VIFC potentially attractive as a domicile for market infrastructure companies.

The sandbox (Decree 324, Article 24 of Resolution 222)#

New trading models — particularly those involving digital assets, blockchain-based settlement, or novel derivative structures — may be deployed through the VIFC's regulatory sandbox before receiving full licensing. This creates a pathway for innovative exchange operators to test products and systems in a controlled environment.

Dispute resolution (Decree 328)#

Commercial disputes arising from exchange-traded transactions can be resolved through the VIFC's International Arbitration Centre or specialised courts, applying foreign governing law where parties have agreed to it. For international trading firms accustomed to resolving disputes under English law or through institutions such as the LCIA or SIAC, this is a meaningful assurance.

AML/CFT (Decree 329)#

All exchange participants are subject to the VIFC's anti-money laundering and counter-terrorism financing requirements. This is particularly relevant for carbon credit trading and NFT markets, where AML risks have attracted regulatory scrutiny globally.

What the VIFC commodity exchange could look like#

Based on the legal framework, the priority sector lists, and public statements from VIFC-HCMC and VIFC Da Nang, the commodity exchange infrastructure within the VIFC is likely to develop along several tracks.

Agricultural and energy derivatives#

Vietnam is the world's second-largest coffee producer, a major rice exporter, and a growing energy market. Exchange-traded futures and options on Vietnamese coffee, rice, rubber, and energy products could serve both domestic hedging needs and attract international speculative and arbitrage flow. Currently, Vietnamese commodity producers and traders manage price risk primarily through offshore exchanges or bilateral OTC contracts — an onshore VIFC exchange would bring that activity within Vietnam's regulatory perimeter.

Carbon and green products#

Vietnam's carbon market is in its early stages, but the government has signalled clear intent to develop exchange-traded carbon instruments. A VIFC-based carbon exchange could position Vietnam as the carbon trading hub for mainland Southeast Asia — a region where demand for carbon credits is growing rapidly as manufacturing supply chains face pressure from European and US carbon border adjustment mechanisms.

Digital asset and NFT trading#

The explicit inclusion of NFTs in Decree 330's scope, combined with the broader digital asset sandbox framework under Decree 324, creates a potential pathway for regulated digital asset exchanges within the VIFC. Da Nang's positioning as the innovation and sandbox hub makes it the likely initial venue for these products.

Multi-asset clearing#

The ambition for a multi-asset clearing and settlement centre is perhaps the most significant long-term infrastructure play. A CCP that can clear across commodities, derivatives, carbon credits, and tokenised assets — using blockchain-based settlement — would be a distinctive capability. No other financial centre in mainland Southeast Asia currently offers this.

What remains to be issued#

Decree 330 establishes the framework, but several operational layers are still needed before a commodity exchange can begin trading:

• Exchange operating rulebooks — trading rules, market surveillance protocols, participant admission criteria, position limit frameworks, and market data policies
• Clearing house rules — default management procedures, margin methodologies, default fund sizing, and member obligations
• Licensing requirements — specific capital adequacy thresholds, technical infrastructure standards, and governance requirements for exchange and clearing house operators
• Product approval procedures — the process for listing new contracts, including the criteria the IFC Management Authority will apply when assessing new product proposals
• Participant categories — the types of membership available (direct clearing member, trading participant, market maker, etc.) and the requirements for each
• Supervisory reporting — the data that exchanges and clearing houses must provide to the IFC Supervisory Authority, and the frequency and format of that reporting

These instruments will likely come from the IFC Management Authority and the IFC Supervisory Authority, potentially in coordination with the SBV (for settlement involving bank accounts) and the Ministry of Finance (for tax treatment of exchange-traded products).

What this means for market participants#

For exchange and infrastructure operators#

Decree 330 creates a greenfield opportunity. There is no incumbent VIFC commodity exchange — whoever builds this infrastructure first will shape the market. The combination of broad product scope (commodities, carbon, NFTs, derivatives), access to a liberalised FX regime, and preferential tax treatment makes the VIFC a credible location for exchange infrastructure investment.

The challenge is execution. Building a commodity exchange requires not just regulatory permission but liquidity, clearing infrastructure, technology, and a critical mass of participants. The legal framework is necessary but not sufficient.

For commodity trading firms#

The ability to trade Vietnamese commodity derivatives on an exchange within the VIFC — in foreign currency, with international clearing standards, and with disputes resolvable under foreign law — would be a meaningful improvement over current arrangements. Firms that currently hedge Vietnamese commodity exposure through SGX or offshore OTC markets should monitor the VIFC exchange development closely.

For carbon market participants#

Vietnam's carbon market is at an inflection point. The legal framework for exchange-traded carbon instruments now exists. Firms active in voluntary carbon markets, compliance carbon markets, or carbon credit origination in Vietnam should evaluate early engagement with the VIFC authorities as operating rulebooks are developed.

For digital asset firms#

The NFT provision in Decree 330, combined with the digital asset sandbox framework, creates a narrow but real pathway for regulated digital asset exchange activity. Firms should note the distinction: NFT trading can operate under the commodity exchange framework, while broader digital asset activity (tokenised securities, stablecoins, DeFi) falls under the sandbox regime.

"Decree 330 turns the VIFC from a regulatory zone into a marketplace. The other decrees tell you how to set up and operate within the centre. This one tells you what you can trade."

This guide was last updated on 14 February 2026. Decree 330 provides the framework for commodity exchanges, but operating rulebooks and licensing requirements have not yet been issued. We will update this guide as new instruments are published. For the banking and FX framework, see our guide to Decree 329 + Circular 72. For the foundational legal framework, see our guide to Resolution 222. For the broader regulatory picture, see our Regulation section.