On October 31, 2026, the Ministry of Finance issued Circular No. 165/2026/TT-BTC (“Circular 165”), providing guidance on certain aspects of the reporting and information disclosure regime in the crypto-asset market, which is being piloted pursuant to the Government’s Resolution No. 05/2025/NQ-CP (“Resolution 05”), taking effect on December 18, 2026. Accordingly, the key policy measures include requiring crypto-asset service providers and issuers to disclose information bilingually, publicly disclose transaction data, and submit reports to the State Securities Commission of Vietnam (“SSC”) on a daily, weekly, monthly, semi-annual, and annual basis.
I. Scope and General Principles (Article 2 and 4)
- Applicable entities: Circular 165 applies to: (i) crypto-asset service providers; (ii) crypto-asset issuers; (iii) organizations and individuals participating in investment and activities in the crypto-asset market; and (iv) other relevant authorities, organizations, and individuals. Accordingly, the majority of reporting and information disclosure obligations are imposed on crypto-asset service providers and issuers.
- Principles of reporting and information disclosure
- Information quality: Information shall be accurate, truthful, timely, complete, and not misleading. Where there is any change to previously reported or disclosed information, the relevant entity shall promptly and fully report or disclose the changes and the reasons therefor.
- Bilingual disclosure: Crypto-asset service providers and issuers shall disclose information simultaneously in Vietnamese and English. In the event of any discrepancy between the two versions, the Vietnamese version shall prevail.
- Record retention: Information that has been reported or disclosed (in written form, if any, and in electronic data format) shall be retained for a minimum period of 10 years. Disclosed information shall be retained and remain accessible on the entity’s website for a minimum period of 05 years.
- Reporting format: When disclosing information, crypto-asset service providers shall simultaneously report the disclosed information to the SSC. Reports shall be submitted either in hard-copy form or in electronic form bearing a valid digital signature through the SSC’s information system.
- Relationship with tax laws: Circular 165 does not replace reporting obligations for tax administration purposes under the Crypto-Asset Reporting Framework; such reporting shall be conducted in accordance with the laws on tax administration. User identification information, tax identification numbers, and transaction information of individual users serving tax administration purposes are not subject to public disclosure, unless otherwise provided by law.
II. Disclosure of Information by Crypto-Asset Service Providers
- Disclosure of transaction information during trading hours (Article 10): During trading hours, crypto-asset service providers shall publicly disclose the following information on their websites: (i) the total number of types of crypto-assets permitted for trading and the status of each type; (ii) the price and volume of the most recent transaction; (iii) the highest and lowest prices during the day; (iv) the extent and indicators of price fluctuations of each type of crypto-asset; (v) at least the three best bid and ask price levels expected to remain after order matching, together with the corresponding expected remaining bid and ask volumes at such price levels; and (vi) the purchase and sale values of foreign investors for each type of crypto-asset.
- Disclosure of information on the immediately preceding trading day: On a daily basis, crypto-asset service providers shall disclose the following information: the total number of types of crypto-assets traded during the day; the extent of price fluctuations of crypto-assets during the trading day; the number of orders, bid and ask volumes, and corresponding values for each type of crypto-asset; and the trading volume and value of each type of crypto-asset, including order-matched transactions and transactions conducted through other methods (if any).
- Selection, cancellation, and restriction of crypto-asset trading (Article 7): Crypto-asset service providers must disclose on their websites the selection of crypto-assets for trading at least 07 days prior to the official trading date. Where a decision is made to cancel or restrict the trading of crypto-assets, the crypto-asset service provider shall disclose information regarding such cancellation or restriction on its website at least 07 days prior to the official date of cancellation or restriction of crypto-asset trading.
- Periodic, extraordinary, and on-request disclosure
- Financial statements: Crypto-asset service providers shall comply with Resolution 05, subject to two additional requirements: where the service provider is a parent company, it shall disclose both its parent company’s financial statements and consolidated financial statements; the audit firm and auditors conducting the audit or review of the financial statements shall be audit firms and auditors approved to audit public-interest entities in the securities sector.
- Amendments to operational procedures: Where certain operational procedures prescribed under Resolution 05 are amended or supplemented, crypto-asset service providers shall publish the amended or supplemented procedures on their websites within 24 hours from the time of issuance.
III. Disclosure of Information by Crypto-Asset Issuers (Article 11): Information of crypto-asset issuers shall be simultaneously disclosed on both the issuer’s website and the website of the crypto-asset service provider. Specifically:
- Disclose the prospectus prior to the offering or issuance; any amendments or supplements to the prospectus shall be disclosed within 24 hours from the time such amendments or supplements are made.
- Announce the results of the offering or issuance within 07 days from the closing date of the offering or issuance, using the form provided in Appendix I attached to Circular 165.
- Disclose any changes to the terms and characteristics of issued crypto-assets within 24 hours from the date of the decision to make such changes.
- Every 06 months, from the closing date of the offering or issuance until all commitments set out in the prospectus have been fulfilled (if any), disclose the status of fulfilment of commitments to investors.
- Notify the crypto-asset service provider with which the crypto-assets are held in custody at least 07 days in advance before repurchasing crypto-assets issued by itself.
IV. Reporting Regime Applicable to Crypto-Asset Service Providers
- Transaction Activity Reports
- Daily: No later than 03:00 pm, report to the SSC the trading activities of the immediately preceding day, using the form provided in Appendix IV (including the number of buy orders, sell orders, matched orders, and cancelled orders; total trading volume and value of each type of crypto-asset; etc.).
- Monthly, on the 10th day: Report to the SSC the market situation for the immediately preceding month, using the form provided in Appendix V (including the number of newly opened and closed accounts, total purchase and sale values, and net purchase or net sale values of each investor group), and simultaneously provide information to the Ministry of Public Security and the State Bank of Vietnam in accordance with Resolution 05.
On the same date, crypto-asset service providers must also report transactions showing signs of violations that have been handled in accordance with the monitoring procedures during the immediately preceding month; proprietary trading activities; issuance offerings; the list of shareholders and institutional capital-contributing members compiled as of the first day of that month; and the custody status of issued crypto-assets.
- Reports on Incidents, Compliance, Personnel, and Insiders
- Information technology incidents (Article 17): Within 24 hours from the detection of an information technology incident affecting the provision of transaction services to customers, report the incident to the SSC, including a description of the incident and the proposed remediation plan.
- Compliance assessment: No later than March 31 of each year, submit to the SSC a compliance assessment report for the immediately preceding year, using the form provided in Appendix XIV.
- Personnel and capital: Within 05 days from any change in the General Director, Chief Technology Officer, or a reduction in the number of personnel in the technology department or personnel holding securities practice certificates working in other professional departments, report such changes to the SSC together with an assessment of the continued satisfaction of licensing conditions. On January 10 of each year, submit the list of technology personnel for the preceding year using the form provided in Appendix III. Any plan to increase or decrease charter capital shall be reported at least 15 days in advance.
- Transactions by insiders: Members of the Board of Directors, Members’ Council, General Director, Chief Technology Officer, and their related persons who intend to trade crypto-assets included in the list of crypto-assets admitted for trading by a crypto-asset service provider must notify that service provider at least 03 days in advance, specifying the expected quantity, timing, and method of the proposed transactions.
