Most of the attention around Vietnam's crypto pilot is going to the obvious question: which company gets one of the first exchange licences?
I think the more useful commercial question is one step earlier.
Who gets paid before the exchange itself makes a single dong from trading fees?
Vietnam's licensing structure almost guarantees that a supplier market has to form before the retail market does. A prospective operator needs at least VND 10 trillion in paid in charter capital. At least 65% of the capital must come from institutional shareholders, more than 35% must come from at least two qualifying institutions, and foreign investors are capped at 49%. The pilot allows a maximum of five licensed market operators.
That makes "open a local exchange" a poor entry thesis for most foreign crypto companies. The capital requirement alone removes almost everyone. But it does not remove the commercial opportunity. It pushes the opportunity down the stack.
The market is spending before it is trading
As of 24 September 2026, Vietnam still has no publicly confirmed fully licensed crypto asset exchange. Five applicants have passed the first dossier review, while regulators are still building the supervision and disclosure framework. CAEX is already running controlled platform testing with staff and partners, while other applicants continue working through licensing requirements.
An exchange cannot wait for the licence before it starts building. It needs the systems, controls, people and counterparties before approval. In practice, the pre licence market already needs exchange technology, custody infrastructure, KYC and KYB, transaction monitoring, blockchain analytics, information security, banking connectivity, liquidity connections, risk systems, training and operating procedures.
The important distinction is between providing a regulated crypto service and selling infrastructure to the company that will provide it.
A foreign custody company should not assume it can custody Vietnamese retail assets directly. It may still be able to sell wallet infrastructure, key management or security technology to a locally licensed operator. The same logic applies to liquidity, compliance and trading technology.
The relationship map is already forming
The public relationships announced so far show where money is likely to move.
| Companies / organisations | Public relationship | What it tells us |
|---|---|---|
| CAEX, VPBankS and LynkiD | VPBankS and LynkiD are founding shareholders. LynkiD supports digital identity and core platform infrastructure. | Local finance and technology are being built into the operator. |
| CAEX and OKX Ventures | OKX Ventures signed an investment agreement and became a strategic shareholder. | A foreign exchange group can enter through capital, technology and liquidity rather than direct operation. |
| CAEX and HashKey | HashKey Capital invested. HashKey Digital Asset Group separately signed a technology agreement giving CAEX exclusive use in Vietnam of its institutional exchange technology. | This is a clear infrastructure play before local trading starts. |
| VPBank and OKX | Strategic cooperation covers digital assets, blockchain, platform development and liquidity connectivity. | The bank relationship may become as important as the exchange relationship. |
| SSI Digital and Bithumb | An MOU covers exchange infrastructure, wallet and custody systems, cybersecurity, risk, compliance and operating know how. | Foreign operational experience is exportable. |
| TCEX and Fireblocks | TCEX says its security architecture uses Fireblocks technology. Contract terms are not public. | Institutional custody and key management are already in the procurement stack. |
| SCEX and VBI Academy | SCEX became technology partner for the Digital Assets Literacy 2026 programme using simulated trading. | Training and simulation can start before live trading. |
| GOE Alliance and Sumsub | An MOU covers compliant crypto payment use cases, identity verification and fraud prevention. | KYC and fraud infrastructure have routes into Vietnam beyond an exchange licence. |
| GOE Alliance and Crystal Intelligence | An MOU focuses on cross border payment infrastructure and blockchain intelligence. | Analytics is becoming part of the institutional layer around the market. |
There are three categories here. An equity investment or signed technology licence is a real commercial commitment. An MOU is evidence of intent, but may or may not become meaningful revenue. Everything beyond that is market inference.
Vietnam's crypto sector is full of announcements. They are useful signals. They are not purchase orders.
The picks and shovels are unusually attractive here
Vietnam's structure makes the supplier opportunity strong because operator requirements are demanding.
I would think about the stack in five layers: market infrastructure, trust infrastructure, financial connectivity, institutional readiness and market readiness.
Market infrastructure means matching engines, wallets, custody technology, APIs and operational tooling. Trust means KYC, AML, blockchain analytics, fraud detection, Travel Rule tooling and cybersecurity. Financial connectivity means VND rails, reconciliation and liquidity. Institutional readiness means audit, legal structuring, governance, accounting, risk and security certification. Market readiness covers staff training, customer education, research and communications.
The last layer needs the most caution.
Vietnam's rules place crypto related advertising and marketing inside the regulated perimeter. Decree 284, effective from 1 September 2026, provides penalties for organisations conducting crypto related services or advertising and marketing without the required licence.
That makes institutional education, stakeholder communications and B2B market preparation cleaner pre licence opportunities than token promotion or mass retail acquisition.
Three types of companies that should enter now
The first is infrastructure companies already selling to regulated financial institutions. Custody technology, security, identity, AML, fraud, analytics and exchange infrastructure fit because the buyer can be the Vietnamese operator rather than the retail customer.
The second is crypto companies with technology or liquidity that can sit behind a local licence. OKX and HashKey already show the pattern. The foreign company contributes capital, systems, experience or liquidity. The Vietnamese entity holds the operating position.
The third is specialist B2B service firms that can help candidates become operational. Cybersecurity, audit, legal support, training, localisation, compliance implementation, research and institutional communications all fit.
The scope needs to be specific. "We will help you launch in Vietnam" is weak. "We will localise your onboarding flow, map compliance gaps and prepare institutional communications before licence approval" is much easier to buy.
Three types that should probably wait
A foreign exchange whose Vietnam plan depends on acquiring retail users under its offshore brand should wait. The structure is moving toward licensed domestic operators.
So should growth agencies whose economics depend on KOL campaigns, referral codes and aggressive retail conversion. That sits too close to the regulated marketing perimeter before the licensed market is operating.
Token projects that assume Vietnam entry means getting listed, buying attention and building a community first should also be careful. Until licensed venues, listing processes, VND rails and enforcement practice become clearer, that sequence creates more risk than advantage.
The first exchange does not need to make the first money
A regulated market does not begin when the first retail trade happens.
It begins months earlier, when institutions start spending money to become capable of making that trade legally.
Vietnam is already in that phase.
The better question for most foreign crypto companies is not, "Can we open an exchange in Vietnam?"
It is: which part of the regulated stack can we own, supply or support before the licence is issued?
For most foreign operators, that is the more realistic market entry strategy. It is also where some of the first real revenue from Vietnam's new crypto market is likely to appear.
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