Vietnam is taking another step toward building a formal regulatory framework for digital assets. The Ministry of Finance of Vietnam has released Circular 15/2026, providing detailed accounting guidance for organizations participating in the country’s pilot program for crypto assets.

The new circular further clarifies the implementation of Resolution 05 on Digital Asset Pilot Program, which outlines Vietnam’s experimental regulatory approach toward the crypto market.

The rules will apply starting March 4, 2026, and will govern financial reporting for the 2026 fiscal year onward until a more comprehensive legal framework replaces the pilot regulations.

Who the Circular Applies To

The accounting guidelines are designed for three main groups operating within Vietnam’s crypto ecosystem.

First are crypto exchanges, which facilitate trading and custody services.
Second are token issuers, including projects that raise capital through token issuance.
Third are domestic institutional investors participating in the digital asset market.

By defining accounting rules for these groups, regulators aim to bring greater transparency and financial discipline to the emerging sector.

Mandatory Separation of Customer Assets

One of the most important provisions focuses on asset segregation.

Under the new rules, crypto assets belonging to customers must be completely separated from assets held by the exchange itself. This requirement is designed to prevent misuse of customer funds and reduce the risk of failures similar to the collapse of FTX in 2022.

The principle mirrors safeguards used in traditional financial markets, where client assets must remain segregated from a firm’s proprietary funds.

Token Issuance Treated as Debt in Certain Cases

The circular also introduces a stricter accounting interpretation for token fundraising.

If a token issuance effectively functions as a capital-raising mechanism, it must be recorded as a liability similar to a loan rather than simple revenue.

In practice, this means organizations issuing such tokens must recognize a financial obligation to repay or deliver equivalent value, rather than treating the funds as unrestricted capital.

This approach aims to discourage token issuers from raising money without clear accountability for how those funds are used.

A Step Toward a Structured Crypto Market

Although Vietnam still lacks a full legal framework for digital assets, the release of Circular 15/2026 signals a gradual move toward clearer regulatory standards.

By establishing accounting rules for exchanges, issuers, and institutional participants, authorities are attempting to introduce financial transparency and risk controls while continuing to observe how the market develops.

If the pilot program proves effective, these guidelines could eventually serve as the foundation for Vietnam’s long-term crypto regulatory regime.

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