The issuance of Circular 15/2026/TT-BTC is not merely a technical move in accounting regulation, but is widely regarded as one of the first building blocks for establishing a transparent and controlled crypto asset market in Vietnam. As the country enters a cautious pilot phase, financial transparency is considered a prerequisite for sustainable market development.
Limited Pilot Scheme and the Race for Market Entry
Under Resolution 05/2025/NQ-CP issued in September 2025, the number of enterprises allowed to participate in the pilot program for crypto asset services is capped at five. This strategic limitation reflects a cautious regulatory approach aimed at controlling risks from the outset.
Out of seven applicants, five companies have been deemed eligible, including VIX Crypto Asset Exchange JSC, Loc Phat Vietnam, Vietnam Prosperity, Techcom, and Vietnam Digital Assets. While final approvals are still pending, these firms are using the interim period to strengthen their operational systems and financial capacity.
According to many experts, limiting the number of participants not only facilitates regulatory oversight but also creates a true sandbox environment where business models can be tested before broader implementation.
Circular 15: Standardizing Accounting and Enhancing Risk Control
Circular 15/2026/TT-BTC, issued by the Ministry of Finance, plays a critical role by providing accounting guidelines for organizations participating in the crypto asset market. Notably, instead of developing a completely new accounting framework, Vietnam has chosen to integrate crypto assets into the existing accounting system.
This approach offers several advantages. It reduces implementation time and leverages established accounting standards. At the same time, incorporating crypto assets into financial reporting allows regulators to better monitor, evaluate, and control capital flows.
Several key aspects of the Circular that businesses must pay close attention to include:
First, the recognition of crypto assets. Companies must clearly determine the nature of their holdings and classify assets based on their intended use, such as investment, custody, or trading.
Second, valuation methods. Crypto assets must be valued based on market prices at the time of recognition, with mechanisms in place to update valuations in response to market fluctuations.
Third, transparency and disclosure requirements. Organizations are required to fully report all crypto-related transactions, including cross-border activities, to support oversight and anti-money laundering efforts.
Fourth, internal controls and risk management. Firms must establish robust internal control systems capable of detecting and preventing fraud or misuse of assets.
Expert Perspectives: “Bringing Crypto into the Framework Is a Major Step Forward”
Many financial experts view Circular 15 as a practical and timely move, especially given that Vietnam does not yet have a dedicated legal framework for crypto assets.
An auditing expert noted that integrating crypto assets into the existing accounting system is a pragmatic approach. It allows regulators to keep pace with market developments while laying the groundwork for more specialized standards in the future.
Meanwhile, blockchain specialists emphasize that the most significant aspect of the Circular lies not in its accounting techniques but in its regulatory message. Requiring transparency in capital flows and comprehensive reporting significantly reduces opportunities for illicit activities.
However, some experts also warn that without standardized valuation mechanisms and reliable market data, financial reporting may still face inaccuracies. This remains a challenge not only for Vietnam but for many countries worldwide.
Persistent Risks in the Market
Despite being a significant step forward, Circular 15 does not eliminate the inherent risks of the crypto asset market.
The anonymity and cross-border nature of transactions make it difficult to trace capital flows, posing major challenges for regulators in combating money laundering and terrorist financing.
In addition, the high volatility of crypto assets can directly impact corporate financial statements. Without strong risk management systems, businesses may face sudden financial shocks.
Market trust is another critical factor. Given past incidents involving non-transparent exchanges, building a reliable and transparent ecosystem is essential.
Vietnam’s Strategic Direction
Vietnam appears to be adopting a gradual and cautious approach rather than rushing into full-scale adoption. The combination of a limited pilot program and regulatory instruments such as Circular 15 demonstrates a clear intention to build a controlled market environment from the beginning.
Compared to many countries, this approach helps minimize systemic risks while allowing regulators to learn and adjust policies based on real-world implementation.
Significance of Circular 15
Circular 15/2026/TT-BTC is not a complete solution to all challenges surrounding crypto assets, but it is a necessary step in moving the market out of a legal gray area. By requiring financial transparency from participating organizations, the foundation for a healthier and more sustainable market can begin to take shape.
During the pilot phase, success will depend not only on the participating enterprises but also on the ability of regulators to monitor and adapt policies effectively. If implemented well, this could become a crucial stepping stone toward building a secure and sustainable digital asset ecosystem in Vietnam.
