The Ministry of Finance is seeking public input on the draft Circular guiding accounting practices for organizations involved in Vietnam’s cryptocurrency market. This pivotal move aims to concretize the legal framework for the pilot phase of the cryptocurrency market, as outlined in Government Resolution No. 05/2025/NQ-CP (Resolution 05). It also addresses the legal vacuum in accounting for this novel, complex, and rapidly evolving asset class.
The Circular applies to cryptocurrency service providers, including market organizers, custodians, issuance platforms, and related service providers; cryptocurrency issuers conducting sales and issuances via licensed platforms; and domestic institutional investors operating under Vietnamese law and participating in the cryptocurrency market.
A key focus of the draft is the principle of segregating and accounting for customer funds and assets from those of the service provider.
Cryptocurrency service providers must meticulously track “Accounts Receivable” for each custodial member, detailing the receivable content and payment instances. They must also recognize revenue from custodial fees, asset management fees, rights execution services, asset transfers, collateral management, and other operational activities.
For proprietary cryptocurrency trading, service providers must record revenues and expenses similarly to securities trading. They are required to maintain detailed records of proprietary cryptocurrency holdings and promptly account for related revenues. Risk provisions for proprietary trading must align with those for securities firms.
Cryptocurrency issuers must account for transactions based on their nature, akin to corporate borrowing activities.
Domestic institutional investors will follow financial investment accounting principles, with account classification and recognition methods depending on investment objectives and holding periods. The draft does not yet extend guidance to individual or foreign investors.
Scheduled for implementation in the 2026 fiscal year, the Circular will remain effective throughout the pilot phase under Resolution 05. This foundational step aims to establish a unified, transparent accounting framework for the emerging market, paving the way for future regulatory enhancements.
Under Resolution 05, cryptocurrencies are defined as digital assets backed by real assets, controlled via private keys, with market value, and tradable only on licensed platforms.
The Ministry of Finance emphasizes the Circular’s necessity, given the absence of specific cryptocurrency accounting guidelines in Vietnamese Accounting Standards. The pilot phase demands a unified understanding of accounting, reporting, and disclosure to ensure financial statement transparency and mitigate legal risks for businesses.
HÃ Ly
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