Daily Reports by 15:00, Wallet Data Every Monday, Incidents Within 24 Hours: Thông tư 165/2026/TT-BTC Sets the Reporting Calendar for Licensed Crypto Exchanges in Việt Nam From 18 December 2026

No licensed crypto exchange has opened in Việt Nam yet, but the reporting calendar it will live by now exists. On 31 October 2026 the Ministry of Finance signed Thông tư 165/2026/TT-BTC, Hướng dẫn một số nội dung về chế độ báo cáo, công bố thông tin trên thị trường tài sản mã hóa (guidance on reporting and information disclosure in the crypto-asset market). The signed copy was posted on the Government’s legal-document portal at the start of this week, after the ministry’s digital signature on 2 November and the Government information agency’s on 3 November, and the first press write-ups appeared today. The circular takes effect on 18 December 2026, 48 days after signature, which is the normal minimum for a central instrument.

The timing is the story. The pilot market under Nghị quyết 05/2025/NQ-CP has had a sanctions decree since 1 September, accounting and tax circulars since the spring, and five exchange applicants that have cleared the first review stage, but still no licence. Thông tư 165 is the regulator’s answer to an obvious question: when the first exchange does open, what will the public see on its website, and what will the Ủy ban Chứng khoán Nhà nước (State Securities Commission, SSC) see every day, every week and every month?

What the document is

Thông tư 165/2026/TT-BTC was signed in Hà Nội by Deputy Minister Nguyễn Đức Chi on behalf of the Minister of Finance, on the proposal of the Chair of the SSC. Its stated legal bases are Luật Doanh nghiệp 59/2020/QH14 (as amended by Luật 03/2022/QH15 and Luật 76/2025/QH15), Nghị quyết 05/2025/NQ-CP itself, and Nghị định 376/2026/NĐ-CP on the organisation of the Ministry of Finance. It runs to four chapters and 19 articles, followed by 14 annex forms, on 30 pages.

The scope is deliberately narrow. Điều 1 says the circular guides reporting and disclosure in the pilot market and nothing else. In particular it does not cover the registration and due diligence of users, the identification of controlling persons, or the collection and exchange of transaction data for tax purposes under the Khuôn khổ báo cáo tài sản mã hóa, the tax-reporting framework modelled on the OECD Crypto-Asset Reporting Framework. That data goes straight to the tax authority in the format and on the timetable set by tax law (Điều 5 khoản 3), and Điều 4 khoản 6 states expressly that per-user identity, tax-residence, tax-number and transaction data collected for tax purposes is not public information under this circular.

It applies to four groups (Điều 2): the tổ chức cung cấp dịch vụ tài sản mã hóa (crypto-asset service providers, which under Nghị quyết 05 means the licensed exchanges that also run custody, proprietary trading and token-issuance platforms), the tổ chức phát hành tài sản mã hóa (issuers), investors and other market participants, and related agencies and persons.

Điều 3 adds eight definitions that are new to Vietnamese secondary legislation in this form: mạng lưới (network), địa chỉ (address), hệ thống khớp lệnh (matching engine), niêm yết tài sản mã hóa (listing, meaning admission to the matching engine), ví tài sản mã hóa (wallet), ví nóng (hot wallet, keys created and used in an environment connected to the internet or another externally reachable network), ví lạnh (cold wallet, the opposite) and bằng chứng dự trữ (proof of reserves, the reconciliation of on-chain balances controlled by the exchange against its total obligations to customers at a point in time).

Where it sits in the crypto pilot stack

Nghị quyết 05/2025/NQ-CP of 9 September 2025 created a five-year pilot in which only exchanges licensed by the Ministry of Finance may serve the Vietnamese market, with 10,000 billion đồng of paid-up charter capital, a foreign-ownership cap of 49%, and a long list of personnel, procedure and IT-security conditions in its Điều 8. The resolution’s Điều 15 khoản 3 already imposed three kinds of disclosure on exchanges: periodic (audited annual accounts within 10 days of the audit report and no later than 90 days after year-end, reviewed half-year accounts within 5 and 45 days, quarterly accounts within 15 days), extraordinary (within 24 hours of a frozen bank account, a suspension, a change to the licence, a court judgment, a tax penalty, a ministry sanction or an IT incident affecting customer trading) and on request.

Around that skeleton the ministry has been adding flesh all year: Quyết định 96/QĐ-BTC of 20 January 2026 opened the licence application window; Thông tư 15/2026/TT-BTC set the accounting rules for market participants; Thông tư 32/2026/TT-BTC and 41/2026/TT-BTC covered tax policy and tax declaration; and Nghị định 284/2026/NĐ-CP, covered here in August, has provided the fine schedule since 1 September 2026. The banking-law amendment Luật 23/2026/QH16, covered in September, separately made crypto-asset providers reporting entities under the anti-money-laundering law.

Thông tư 165 is the layer that turns the resolution’s three-line disclosure duty into a calendar with forms. Several of its articles simply point back to the resolution (Điều 7 khoản 1 to the licence-grant and revocation announcements in Điều 10 khoản 5 and Điều 12 khoản 4; Điều 8 khoản 1 and Điều 9 khoản 1 and 2 to the periodic, extraordinary and on-request categories in Điều 15 khoản 3) and then add what the resolution left open.

What a licensed exchange must publish

Live, during trading hours (Điều 10 khoản 1), on its own website: the total number of crypto assets admitted to trading and the status of each; the price and volume of the most recent trade; the day’s high and low; the size and sign of the price change for each asset; at least the three best bid and three best ask levels expected to remain after matching, with the volumes behind them; and the buy and sell values of foreign investors per asset.

Every day (Điều 10 khoản 2), a summary of the previous trading day: the number of assets admitted, the price range, the number of orders and the volumes and values of buy and sell orders per asset, and the matched volume and value, separating order-book matches from trades executed by other methods.

Listing and delisting (Điều 7 khoản 2 and 3): an exchange must announce on its website its decision to admit a crypto asset to trading at least 7 days before trading starts, and must give the same 7 days of notice before it cancels or restricts trading in an asset.

Financial statements (Điều 8): on the timetable in the resolution, with the added rules that an exchange that is a parent company must publish both its own and consolidated statements, and that the auditor must be one approved to audit public-interest entities in the securities sector.

Procedures (Điều 9 khoản 3): when an exchange amends any of the procedures listed in points b, c, d, g and k of Điều 8 khoản 6 of the resolution, which are its issuance-platform, custody, trading-and-settlement, disclosure and conflict-of-interest-and-complaints procedures, it must post the amended version within 24 hours of adopting it. Under the resolution such amendments may only be adopted after the ministry has given its opinion.

Principles (Điều 4): disclosures must be accurate, truthful, timely, complete and not misleading, and any change must be disclosed with the reason. Everything published under Điều 7 to 9 must be reported to the SSC at the same time. Exchanges and issuers must publish simultaneously in Vietnamese and English, the English text must match, and the Vietnamese text prevails in case of conflict. Disclosed and reported material must be retained for at least 10 years, and disclosures must remain accessible on the website for at least 5 years. Disclosure is made through one legal representative or one person authorised by the legal representative, who remains responsible. The only ground for postponing a disclosure is force majeure (natural disaster, fire, war, epidemic), reported to the SSC immediately and caught up as soon as the event is over (Điều 6).

What it must report to the State Securities Commission

Chapter III is the regulator-facing half, and it is where the operational burden sits. The cadences, with the annex form in brackets:

Every trading day by 15:00, the previous day’s trading (Phụ lục IV). The form asks, per asset, for order counts and matched-order counts, opening, closing, high, low and average prices, matched volume and value, and the value of matches within ±2% of the opening price; for trades by other methods; for a breakdown of trading by domestic and foreign, individual and institutional investors and the exchange’s own proprietary desk; and for the distribution of matched orders by size in five bands: under 1 million đồng, 1 to under 10 million, 10 to under 100 million, 100 million to under 1 billion, and 1 billion đồng and above.
Every Monday, custody data for the previous week (Phụ lục VII), measured at 17:00 on Sunday: customer holdings by investor type, split between hot wallets, cold wallets and other arrangements, plus pending balances; the exchange’s own holdings, split between proprietary trading and other uses; every custody wallet by asset, network, address and wallet type; proof of reserves “if any”, with the block number, the actual reserve ratio, customer and firm balances and any insurance cover; transfers to and from other domestic exchanges; deposits and withdrawals succeeded, failed and pending; and the lists of listed and unlisted assets held.
On the 10th of every month: the list of institutional shareholders as at the 1st (Phụ lục II); the market report for the previous month (Phụ lục V), which also goes to the Bộ Công an and the Ngân hàng Nhà nước as the resolution requires; transactions showing signs of violation that the exchange’s own surveillance procedure handled in the month (Phụ lục VI, with a case code, description, number of persons involved, asset, period, volume, value and status); proprietary trading (Phụ lục XI); token issuances on its platform (Phụ lục XII, also to the police and the central bank); and the custody position of assets issued through licensed exchanges (Phụ lục XIII).
By 10 January each year, the staffing of the technology department and of securities-licensed staff in the business departments for the previous year (Phụ lục III).
By 31 March each year, a compliance self-assessment for the previous year (Phụ lục XIV).
Within 60 days of 30 June and 31 December, a semi-annual report on customer assets (Phụ lục X), with opening and closing balances, the custody wallets at period end, proof of reserves “if any” and an audit opinion “if any”.
Event-driven: within 5 days of a change of chief executive or chief technology officer, or any reduction in technology staff or securities-licensed staff, a report with a self-assessment against the licence conditions in Điều 8 khoản 5 of the resolution (chief executive with at least 2 years in a financial-sector business unit, technology chief with at least 5 years in IT, at least 10 information-security-qualified technology staff and at least 10 securities-licensed staff); at least 15 days before any increase or decrease in charter capital; before any change in operations that affects the segregation of customer assets or the allocation between hot and cold wallets (Phụ lục VIII), except when handling an incident under a published procedure; at least 7 days before using another exchange’s custody service (Phụ lục IX); and, under Điều 17 khoản 1, within 24 hours of detecting an IT incident that affects the execution of customer trades, with a description of the incident and the remediation plan.

Reports go to the SSC on paper or as digitally signed electronic documents through the commission’s information system (Điều 5 khoản 2). A footnote to the daily form says the SSC will specify the data-file format; the consultation file records that the commission is still building its online disclosure system for this market and that, until it is connected, exchanges send reports directly.

Issuers, insiders and banks

For issuers (Điều 11), disclosures go on both the exchange’s website and the issuer’s own. The prospectus is published under Điều 6 khoản 3 of the resolution, which means at least 15 days before the offering, and the resolution also limits offerings and issuances to foreign investors. Any amendment to the prospectus must be disclosed within 24 hours; the results of the offering within 7 days of its close (Phụ lục I); any decision to change the terms or features of an issued asset within 24 hours; and progress against commitments made in the prospectus every 6 months until they are fulfilled. An issuer planning to buy back its own asset must tell the custodian exchange at least 7 days in advance (Điều 18 khoản 2).

For insiders (Điều 18 khoản 1), members of the board or members’ council, the chief executive, the technology chief and their related persons as defined in Luật Doanh nghiệp must notify the exchange at least 3 days before trading any asset on its list, stating the quantity, the timing and the method. The consultation summary explains the rationale: insiders know what will be listed next, the trading data, the liquidity of the system and the activity of market makers.

For banks holding the dedicated accounts of foreign investors (Điều 18 khoản 3), the circular points to Điều 13 khoản 9 of the resolution: a quarterly summary of receipts and payments on those accounts to the ministry, the police and the central bank by the 10th of the first month of each quarter.

What changed between the draft and the final text

The ministry and the SSC published the draft in mid-September 2026 with comments due by 26 September, and later posted a summary of 43 groups of comments from Techcombank and the exchange applicants CAEX, SCEX and TCEX. Reading that summary against the signed text:

The 1% shareholder rule is gone. The draft required anyone holding 1% or more of an exchange to report at least 3 days before changing their stake; the industry asked for 5%, in line with securities law, and the SSC removed the clause altogether, noting that an exchange that becomes a public company falls under the securities disclosure regime anyway.
No 9:00 deadline. The draft required the previous day’s summary by 9:00; the final text says “every day”, on the reasoning that the market trades 24/7. The “average price” item was dropped from the live display.
Listing notices moved from after-the-fact to advance. The draft required a report to the ministry, the police and the central bank within 24 hours of a decision to admit or remove an asset; the final text instead requires 7 days of public notice before a listing, a delisting or a restriction, with reporting per the resolution.
The customer-asset report was relaxed. The draft set fixed dates of 31 January and 31 July and described the report as audited; the final text gives 60 days from period end and leaves the audit and the proof of reserves to the exchange’s choice, because the resolution already requires audited and reviewed financial statements.
Order-size bands are in đồng. The draft used four US-dollar bands (under 1,000; 1,000 to 5,000; 5,000 to 10,000; over 10,000); the final uses five đồng bands, after comments asking for đồng or a reference rate.
The incident clock starts at detection. The incident duty moved from Điều 13 to Điều 17, now covers any IT incident affecting customer trades rather than only incidents affecting business continuity, and must include a remediation plan. The drafters kept the resolution’s term “sự cố công nghệ thông tin” rather than adopting the industry’s proposed “sự cố hệ thống”.
Prospectus amendments tightened from 3 days in the draft to 24 hours.
Kept against industry objections: the bilingual requirement; the public display of foreign-investor trading values; wallet addresses in the weekly report (confidential to the SSC, not public); the narrow force-majeure ground for postponement; the quarterly reporting deadline, which the industry wanted extended by 5 days; and the insider rule, which applies to all assets custodied at the exchange across all accounts. A request to add a procedure for freezing or recovering assets at the request of authorities was declined as a property-law matter outside the circular’s scope.

Who it affects and what to do before 18 December

The immediate addressees are the five applicants that passed the first review stage: CAEX of the VPBank ecosystem, which raised its charter capital from 25 billion to 10,000 billion đồng in April 2026 and is reported to be the only one to have met the capital condition; SCEX (Sacom, formerly Lộc Phát), which went from 360 billion to 5,000 billion đồng in August; VIXEX; TCEX of the Techcombank ecosystem; and Tài sản số Việt Nam, majority-owned by Sun Group. The ministry’s May 2026 letters asked all five for the remaining documents under Điều 9 of the resolution, including level-4 information-system security certification, and told them to strip unrelated business lines from their registrations. The consultation file describes the market as piloting “with five service providers”; as of today no licence has been publicly announced. The SSC’s Tô Trần Hòa has said the investor-side fines in Nghị định 284 only apply once a first exchange is licensed, with a six-month transition after that.

For those five, the practical work is a compliance build with 14 forms and four cadences. The weekly custody report is the hardest part: by Sunday 17:00 each week the exchange must be able to enumerate every custody address by network, reconcile hot and cold balances to customer and proprietary holdings, and show deposits and withdrawals including failures. Proof of reserves itself is optional, but the data the form demands is most of a proof of reserves. The daily report by 15:00, the five-band order-size distribution and the ±2% matched-value field imply that the matching engine must produce regulator-grade statistics from day one, and the bilingual rule means the English website is not a later phase.

For investors, the circular describes what a licensed exchange will look like from the outside: live depth of three levels on each side, the foreign flow per asset, a token listing or delisting announced a week ahead, audited accounts, and an IT incident disclosed within 24 hours. None of this exists on the offshore platforms Vietnamese users trade on today.

For enforcement, Nghị định 284/2026/NĐ-CP already fines organisations 100 to 150 million đồng for providing inaccurate or incomplete information to regulators or investors, 30 to 50 million for failing to publish required procedures, and up to 200 million for issuers that breach disclosure duties. Thông tư 165 gives those provisions concrete deadlines to attach to.

Open questions

18 December arrives before any exchange exists. The circular’s obligations attach to licensed providers, so in practice the clock starts on the day of the first licence, but the circular does not say so, and the ministry has not published a licensing date.
The SSC system is not live. Reports in the interim are paper or signed electronic documents sent directly to the commission, and the data-file format for the daily and weekly reports is still to be specified.
Trading day in a 24/7 market. Phụ lục IV defines the reporting day as 0:00 to 24:00, so the 15:00 deadline gives 15 hours after midnight; whether “giờ giao dịch” in Điều 10 means all hours for a continuous market is implied rather than stated.
Optional proof of reserves. The form exists, the definition exists, and the field says “if any”. Whether a licence condition or a later circular makes it mandatory is the obvious next step.
Two surveillance streams. The monthly report of transactions showing signs of violation is the exchange’s own market-surveillance output under its licensed procedure. It is distinct from suspicious-transaction reporting under the anti-money-laundering law, which now applies to crypto providers through Luật 23/2026/QH16, and from the tax-reporting framework that Điều 1 excludes. Exchanges will be running three parallel reporting pipelines with different recipients.

Sources

This post is general information, not legal advice.