A concise summary of the 6procedural steps, filing set, and timelines to apply for, publish, and operationalize the License to organize a cryptocurrency exchange under Government Resolution No. 05/2025/NQ-CP (9 Sep 2025).

Registration procedure for granting a license to provide services for organizing Cryptocurrency Exchange

Step 1- Submit the initial dossier (to SCC) ^[1]

According to Article 10.1,Register organizations are required to submit 01 original Vietnamese sets (or copies - must be from the original book or certified) to the State Securities Commission (SSC) via in‑person filing, post, the National Public Service Portal, or the Administrative Procedure Information System. The document set includes:

(i) Application for a license to provide services to organize a cryptocurrency exchange according to Form No. 02 of the Appendix issued with this Resolution, together with the Charter of the registering organization^[2];

(ii) Certificate of business registration issued by a competent state agency in case this document has not been posted on the National Business Registration Information Portal^[3];

(iii) List of personnel according to Form No. 05 and Personal information sheet according to Form No. 06 of the Appendix issued with this Resolution meeting the provisions in Clause 5, Article 8 ^[4]of this Resolution; labor contracts of these personnel;^[5]

(iv)The procedure, includes the following business processes:^[6]

- Risk management and information security process;

- Process of providing cryptocurrency issuance platform services;

- Process of depositing and managing customer assets;

- Transaction and payment process;

- Self-employment process;

- Procedures for preventing and combating money laundering, terrorist financing, and proliferation of weapons of mass destruction;

- Information disclosure process;

- Internal control process;

- Transaction monitoring process;

- Procedures for preventing conflicts of interest, handling customer complaints, and compensating customers.

Step 2 – MOF response^[7]

Within 20 days from the date of receipt of complete and valid documents specified on Article 9.1, 9.2, 9.5and 9.6^[8] of Resolution05/2025/NQ-CP, The Ministry of Finance shall issue a document on the organization registering to carry out the procedures specified in Article 9.3 Resolution 05/2025/NQ-CP.

Incase the dossier is not complete and valid, the Ministry of Finance shall issue a written reply stating the reasons.

Step 3 - Submit the supplemental dossier ^[9]

Within12 months after the Ministry of Finance has issued the document specified in Article 9.2, Resolution 05/2025/NQ-CP. the registering organization shall continue to submit the following documents:

(i) List of shareholders and capital contributors according to Form No. 03 of the Appendix issued with this Resolution, together with the following documents:

-Certificate of business registration or equivalent document for organizations in case this document has not been posted on the National Business Registration Information Portal; audited financial statements of the 2 previous years of the capital contributing organization;

-Minutes of capital contribution agreement, showing information meeting the conditions:

+ At least 65% of the charter capital must be contributed by shareholders and members who are organizations, of which over 35% of the charter capital must be contributed by at least 02 organizations such as commercial banks, securities companies, fund management companies, insurance companies, and enterprises operating in the technology sector;

+ Shareholders and capital contributing members that are organizations must have legal status and profitable business operations for 2 consecutive years prior to the year of application for a license; the financial statements of the 2consecutive years prior to the year of application for a license must be audited and the audit opinion must be an opinion of full approval;

+ Organizations and individuals are only allowed to contribute capital to 01organization providing cryptocurrency services licensed by the Ministry of Finance;

+ The total capital contribution and share purchase of foreign investors in cryptocurrency service providers must not exceed 49% of the charter capital of the cryptocurrency service provider;^[10]

(ii)Explanation of facilities according to Form No. 04 of the Appendix issued with this Resolution, together with documents proving ownership of the headquarters, right to use the headquarters or headquarters lease contract^[11];

(iii) Appraisal document of the Ministry of Public Security on the application for level 4 information system security of the registered organization^[12];

(iv) Documents proving capital contribution in Vietnamese Dong as prescribed in Article8.2 of Resolution 05/2025/NQ-CP ^[13]; audited annual financial statements or audited contributed charter capital statements at the most recent time.^[14]

Step 4 - Appraisal & License^[15]

Within30 days from the date the Ministry of Finance receives all documents specified in Article 9 of Resolution 05/2025/NQ-CP, The Ministry of Finance shall coordinate with the Ministry of Public Security and the State Bank of Vietnam to review the dossier and issue a License to provide services to organize the cryptocurrency exchange according to Form No. 07 of the Appendix issued with this Resolution;

Incase of refusal, the Ministry of Finance shall respond in writing and state the reasons.

Step 5 - Post - Licensing disclosures^[16]

Within 07 working days from the date the Ministry of Finance issues the License to p The registered organization must publish information about the official date of providing cryptocurrency services to investors on the Ministry of Finance's electronic information page and 01 electronic or printed newspaper in 03 consecutive issues.

At the same time, the registered organization must post on the enterprise's electronic information page and the Ministry of Finance's electronic information page:

- The procedures:

+ Process of providing cryptocurrency issuance platform services;^[17]

+ Process of depositing and managing customer assets^[18];

+ Transaction and payment process^[19];

+ Information disclosure process^[20];

+ Procedures for preventing conflicts of interest, handling customer complaints, and compensating customers.^[21]

- The audited annual financial statements or the audited contributed charter capital report at the most recent time specified in Clause8, Article 9 of the Resolution 05/2025/NQ-CP.

Step 6 - Commence operations ^[22]

After30 days from the date the Ministry of Finance issues the License to provide services for organizing cryptocurrency exchange, The registered organization must operate under the License to provide services for organizing cryptocurrency exchange, except in cases of force majeure; if it fails to operate after this period, the Ministry of Finance shall carry out procedures to revoke the License to provide services for organizing cryptocurrency exchange in accordance with the provisions of Article 12 of  Resolution 05/2025/NQ-CP .

Note: Please note that the above procedure is based on current legislation. Since this process is newly implemented and lacks detailed guiding regulations, additional steps or documentation may be required in practice as determined by the competent authorities.

^[1] Article10.1 Resolution 05/2025/NQ-CP;

^[2] Article9.1  Resolution 05/2025/NQ-CP;

^[3] Article9.2 Resolution 05/2025/NQ-CP

^[4] a) The General Director (Director) has at least 02 years of experience working in the professional department of organizations in the fields of finance, securities, banking, insurance or fund management;

b) The Chief Technology Officer (or equivalent position) has at least 05 years of experience working in the information technology department of organizations in the fields of finance, securities, banking, insurance, fund management or enterprises operating in the technology field;

c) Have at least 10 employees working in the technology department with diplomas and training certificates in network information security meeting the provisions of Article 50 of the Law on Network Information Security; have at least 10 employees with securities practice certificates working in other professional departments.

^[5] Article8.5, 9.5 Resolution 05/2025/NQ-CP;

^[6] Article8.6, 9.6 Resolution 05/2025/NQ-CP;

^[7]Article 10.2, Resolution 05/2025/NQ-CP;

^[8]List of documents in Step 1;

^[9]Article 10.3 Resolution 05/2025/NQ-CP;

^[10]Article 8.3, 9.3 Resolution 05/2025/NQ-CP;

^[11] Article 9.4 Resolution 05/2025/NQ-CP;

^[12] Article 9.7 Resolution 05/2025/NQ-CP;

^[13] The charter capital contribution must be in Vietnamese Dong and the minimum contributed charter capital must be10,000 billion Vietnamese Dong;

^[14] Article 9.8 Resolution 05/2025/NQ-CP;

^[15] Article 10.4 Resolution05/2025/NQ-CP;

^[16] Article 10.5 Resolution05/2025/NQ-CP;

^[17] Article 8.6b Resolution05/2025/NQ-CP;

^[18] Article 8.6c Resolution05/2025/NQ-CP;

^[19] Article 8.6d Resolution05/2025/NQ-CP;

^[20] Article 8.6g Resolution05/2025/NQ-CP;

^[21] Article 8.6k Resolution05/2025/NQ-CP;

^[22] Article 10.6 Resolution05/2025/NQ-CP.