CIRCULARS
GUIDELINES ON ACCOUNTING PRINCIPLES FOR ORGANIZATIONS PARTICIPATING IN THE CRYPTOCURRENCY MARKET IN VIETNAM
Based on the Accounting Law No. 88/2015/QH13, as amended and supplemented by Law No. 56/2024/QH15;
Based on the Law on Industry and Technology No. 71/2025/QH15;
Based on Resolution No. 52-NQ/TW dated September 27, 2019, of the Politburo on a number of guidelines and policies for proactively participating in the Fourth Industrial Revolution;
Based on Resolution No. 57-NQ/TW dated December 22, 2024, of the Politburo on breakthroughs in the development of science, technology, innovation, and national digital transformation, defining the vision until 2045;
Based on Resolution No. 05/2025/NQ-CP dated September 9, 2025, of the Government on the pilot implementation of the cryptocurrency market in Vietnam;
Based on Government Decree No. 29/2025/ND-CP dated February 24, 2025, regulating the functions, tasks, powers, and organizational structure of the Ministry of Finance, as amended and supplemented by Decree No. 166/2025/ND-CP;
As requested by the Director of the Department of Accounting and Auditing Management and Supervision;
The Minister of Finance has issued a Circular guiding accounting principles for organizations participating in the cryptocurrency market in Vietnam.
Article 1. Scope
1. This Circular provides guidance on accounting principles for organizations participating in the cryptocurrency market in Vietnam during the pilot implementation period, in accordance with the provisions and scope of Resolution No. 05/2025/NQ-CP dated September 9, 2025, of the Government on the pilot implementation of the cryptocurrency market in Vietnam (hereinafter referred to as Resolution No. 05/2025/NQ-CP).
2. This Circular does not apply to the determination of tax obligations of organizations participating in the cryptocurrency market in Vietnam to the state budget.
Article 2. Subject of application
This Circular applies to organizations providing crypto asset services, organizations issuing crypto assets, and domestic investors that are organizations established and operating in accordance with Vietnamese law and participating in the crypto asset market in Vietnam.
Article 3. Regulations on the use of terminology
The terms used in this Circular are understood in accordance with Resolution No. 05/2025/NQ-CP; in cases where not specifically defined, they are understood according to the economic nature of the transaction for accounting purposes.
Article 4. General principles of accounting, preparation and presentation of financial statements
1. Organizations providing crypto asset services, organizations issuing crypto assets, and domestic investors must fully comply with the provisions of the Accounting Law, Vietnamese accounting standards, the Enterprise Accounting System, and relevant legal regulations on the crypto asset market.
2. Organizations providing crypto asset services, organizations issuing crypto assets, and domestic investors shall conduct accounting in accordance with the Enterprise Accounting System issued together with Circular No. 99/2025/TT-BTC dated October 27, 2025, of the Minister of Finance and the provisions of this Circular to record accounting entries, prepare and present financial statements.
3. In cases where the issuer of crypto assets and the domestic investor are enterprises or organizations applying their own accounting system, they shall continue to follow that accounting system and the regulations in this Circular for accounting, bookkeeping, preparation and presentation of financial statements.
Article 5. Guidance on accounting principles for organizations providing cryptographic asset services.
1. Organizations providing crypto asset services record revenue from providing services such as organizing crypto asset trading markets, crypto asset custody, and providing crypto asset issuance platforms in the "Revenue from sales and services" account.
Sales revenue and service provision must be tracked in detail for each type of service and business activity of the crypto asset service provider. The crypto asset service provider must classify, track, and account for accounts receivable in detail to take timely measures for recovery and establish provisions for doubtful accounts receivable in accordance with the law.
2. Regarding the custody of crypto assets:
a) The cryptocurrency service provider is responsible for managing and accounting separately for customers' cryptocurrency assets and funds from the service provider's own cryptocurrency assets and funds. Simultaneously, it must track cryptocurrency assets in detail for each customer and each type of cryptocurrency.
b) Cryptocurrency assets held in custody by clients at a cryptocurrency service provider are not recognized as assets of the service provider but are tracked in detail for management purposes and disclosure in financial statements.
c) The organization providing crypto asset services must keep detailed records of the "Accounts Receivable" accounts of its custodian members, broken down by individual receivables, receivable items, and payment transactions.
d) Organizations providing crypto asset services recognize revenue from fees for custody services, fees for managing crypto assets of customers, services for exercising rights, transferring crypto assets to customers, services for managing collateral assets, and other custody service revenue.
3. Regarding proprietary trading of crypto assets:
a) Organizations providing crypto asset services record revenue and expenses from their crypto asset trading activities in a manner similar to securities trading. This analogy is solely for accounting purposes and does not imply that crypto assets are considered securities.
b) Organizations providing crypto asset services must keep detailed records of the types of crypto assets they hold in their proprietary trading, and fully and promptly account for all income from crypto asset trading activities.
c) Organizations providing crypto asset services shall make provisions for risks related to crypto asset trading activities similar to securities trading activities of securities companies.
Article 6. Guidelines on accounting principles for issuers of crypto assets
The issuer of a cryptocurrency conducts the offering and issuance of the cryptocurrency through a cryptocurrency issuance platform based on the nature of the obligations arising from the issued cryptocurrency and the purpose of holding the cryptocurrency, in order to account for it appropriately. If the cryptocurrency has the nature of a capital raising activity, the accounting should be similar to a company's borrowing activities.
Article 7. Guidance on accounting principles for investors
Domestic investors participating in cryptocurrency trading platforms provided by cryptocurrency service providers can buy and sell cryptocurrencies, and their accounting practices are similar to those of financial investments. Accounting should be based on the purpose of the investment and the holding of the cryptocurrencies.
Article 8. Effective date and implementation
1. This Circular takes effect from the date of signing and applies from fiscal year 2026 until amended, supplemented, or replaced by relevant legal regulations.
In the event that the legal documents cited in this Circular are amended, supplemented, or replaced, the new amended, supplemented, or replaced documents shall be followed.
2. The Director of the Accounting and Auditing Supervision Department; the Chairman of the State Securities Commission; the General Director (Director) of the crypto asset service provider, the crypto asset issuer, domestic investors, and the heads of relevant units are responsible for implementing this Circular.
3. During the implementation process, in case of difficulties or obstacles, please promptly report them to the Ministry of Finance for consideration and resolution.