Vietnam Ministry of Finance makes client-asset segregation a hard control in the crypto-asset pilot
Circular 15/2026/TT-BTC does more than standardize bookkeeping. It requires service providers to separate customer cash and crypto from house assets, maintain customer- and asset-level detail, and avoid recognizing custodial client crypto as provider assets—public proof that Vietnam’s pilot expects auditable custody and treasury boundaries, not venue rhetoric.
Key takeaways
- • Vietnam’s Ministry of Finance has moved the crypto-asset pilot from market-design language into auditable operating rules.
- • Circular 15/2026/TT-BTC requires service providers performing custody to separate customer cash and crypto assets from house assets, track them by customer and asset type, and avoid recognizing custodial customer crypto as provider assets.
- • In a pilot where only Ministry-licensed entities can run crypto-asset market services and issuance, trading, and settlement must be conducted in Vietnamese đồng, that accounting treatment matters as public proof of who holds what, what belongs to whom, and what can be reconciled at close.
Trigger
Hướng Dẫn Kế Toán Cho Tổ Chức Tham Gia Thị Trường Tài Sản Mã Hóa
On 7 March 2026, the Government policy portal summarized Circular 15/2026/TT-BTC, issued by Vietnam’s Ministry of Finance on 4 March 2026. The circular applies to organizations participating in Vietnam’s pilot crypto-asset market under Government Resolution 05/2025/NQ-CP. The key custody provisions are specific: segregated accounting for customer cash and crypto, customer- and asset-level subledgers, no recognition of custodial customer crypto as provider assets, and detailed tracking of receivables and custody-fee income.
Open source documentSN Desk view
The Ministry of Finance has now made asset-boundary discipline explicit inside the pilot’s operator stack. Earlier public signals focused on controlled entry: the ministry said in August 2025 that more than one exchange would be permitted but the field would remain limited, and the September 2025 pilot framework capped selection at up to five providers with defined requirements for custody, customer-asset management, transactions, payments, internal control, transaction monitoring, and conflict handling.
January 2026 procedures then turned licensing from policy outline into an administrative process handled through the State Securities Commission. Against that backdrop, the March 2026 circular narrows the interpretive room. A provider may run custody and self-dealing within the pilot perimeter, but it must keep customer assets analytically separate from house positions and revenue accounts. That matters because Vietnam’s pilot is already built around Ministry licensing and VND settlement rather than open-ended venue experimentation. The new accounting rules therefore strengthen the reading that viable operators will be judged less by branding or exchange-launch announcements and more by whether they can evidence client-asset segregation, ledger granularity, and reconciled close across custody, trading, settlement, and reporting. The March 2026 circular therefore gives institutional readers a cleaner answer to a live question: whether Vietnam’s crypto-asset pilot is developing real control architecture. As of 7 March 2026, the answer is yes—but the public proof is custody accounting discipline, not tokenization rhetoric.