Circular 165/2026/TT-BTC guiding reporting and information disclosure on crypto-asset market

CIRCULAR

Guiding a number of provisions on the reporting and information disclosure regime on the crypto-asset market

Pursuant to the Law on Enterprises No. 59/2020/QH14 as amended and supplemented by Law No. 03/2022/QH15 and Law No. 76/2025/QH15 (hereinafter referred to as the Law on Enterprises);

Pursuant to the Government’s Resolution No. 05/2025/NQ-CP on piloting the crypto asset market in Vietnam (hereinafter referred to as Resolution No. 05/2025/NQ-CP);

Pursuant to the Government’s Decree No. 376/2026/ND-CP defining the functions, tasks, powers, and organizational structure of the Ministry of Finance;

At the proposal of the Chairperson of the State Securities Commission;

The Minister of Finance hereby promulgates the Circular guiding a number of provisions on the reporting and information disclosure regime on the crypto-asset market.

Chapter I

GENERAL PROVISIONS

Article 1. Scope of regulation

1. This Circular guides a number of provisions on reporting and information disclosure on the crypto-asset market piloted under Resolution No. 05/2025/NQ-CP.

2. This Circular does not govern the registration and due diligence of crypto-asset users and controlling persons, or the collection, aggregation, retention, reporting, and exchange of information for tax administration purposes under the Crypto-Asset Reporting Framework.

Article 2. Subjects of application

This Circular applies to organizations and individuals related to the activities prescribed in Article 1 of this Circular, including:

1. Crypto-asset service providers.

2. Crypto-asset issuers.

3. Organizations and individuals participating in crypto-asset investment and operating on the crypto-asset market.

4. Other relevant agencies, organizations, and individuals.

Article 3. Interpretation of terms

In this Circular, the terms below are construed as follows:

1. Network means a technological infrastructure comprising connected components operated in accordance with the rules of a distributed ledger or functionally equivalent technology, enabling the generation, validation, recording, retention, and transfer of crypto-assets.

2. Address means a unique, publicly identifiable string of characters on a network, used to identify the address for recording and transferring crypto-assets on such network.

3. Matching engine means a system that receives, processes, and matches buy and sell orders for crypto-assets in accordance with rules pre-established by a crypto-asset trading market organizing service provider.

4. Listing of crypto-assets means the admission of crypto-assets to trading on the matching engine of a crypto-asset trading market organizing service provider.

5. Crypto-asset wallet (wallet) means a device or system used to generate, store, and use cryptographic keys for the purpose of controlling crypto-assets and exercising rights related to crypto-assets.

6. Hot wallet means a type of crypto-asset wallet in which cryptographic keys are generated, stored, and used in an environment connected to the Internet or another externally accessible network.

7. Cold wallet means a type of crypto-asset wallet in which cryptographic keys are generated, stored, and used in an environment not connected to the Internet or any other externally accessible network.

8. Proof of reserves means the reconciliation result between the on-chain crypto-asset balance controlled by a crypto-asset service provider and its total liabilities to clients at a specified point in time.

Article 4. Principles of reporting and information disclosure on the crypto-asset market

1. The reporting and disclosure of information on the crypto-asset market must be accurate, truthful, timely, complete, and not misleading. In case of any change to previously reported and disclosed contents, the party subject to reporting and information disclosure must promptly and fully report and disclose the changed contents and the reasons for such change.

2. When disclosing information in accordance with Articles 7, 8, and 9 of this Circular, a crypto-asset service provider must simultaneously report to the State Securities Commission on the contents of the disclosed information.

3. Crypto-asset service providers and crypto-asset issuers must disclose information simultaneously in both Vietnamese and English. Information disclosed in English must be consistent with the contents of information disclosed in Vietnamese. In case of any discrepancy or difference in interpretation between the Vietnamese and English information, the Vietnamese version shall prevail.

4. Crypto-asset service providers and crypto-asset issuers shall be responsible for preserving and retaining disclosed and reported information in written form (if any) and electronic data for a minimum period of 10 years. The disclosed information of crypto-asset service providers and crypto-asset issuers must be retained and remain accessible on their websites for a minimum period of 05 years.

5. When carrying out information disclosure obligations under the guidance of this Circular, a crypto-asset service provider or crypto-asset issuer must carry out information disclosure through 01 legal representative or 01 individual duly authorized by the legal representative in accordance with regulations. The legal representative shall be responsible for the completeness, accuracy, and timeliness of the information disclosed by the authorized person.

6. The carry out of reporting and information disclosure under this Circular shall not substitute for the obligations of registration, due diligence, collection, record retention, and reporting of information for tax administration purposes. Identification information, tax residence, tax identification numbers, information on controlling persons, and transaction information of each user collected and reported for tax administration purposes under the Crypto-Asset Reporting Framework shall not constitute information subject to public disclosure under this Circular, unless otherwise provided by law.

Article 5. Methods of reporting and information disclosure

1. Means of information disclosure include: the website of the enterprise; the information disclosure system of the State Securities Commission; and other mass media in accordance with law.

2. The State Securities Commission is the unit under the Ministry of Finance responsible for receiving reports and disclosed information from crypto-asset service providers within the scope of regulation of this Circular. Crypto-asset service providers shall submit reports in paper form or in the form of electronic documents bearing valid digital signatures in accordance with law via the electronic information system of the State Securities Commission.

3. Reports for tax administration purposes under the Crypto-Asset Reporting Framework shall be submitted directly to tax authorities in accordance with the methods, data formats, and time limits prescribed by the law on tax administration.

Article 6. Postponement of information disclosure

1. The party subject to information disclosure may postpone information disclosure in case of force majeure reasons such as natural disasters, fires, wars, or epidemics. A crypto-asset service provider must report to the State Securities Commission on the postponement of information disclosure immediately upon the occurrence of the event (clearly stating the reasons for the postponement of information disclosure), and simultaneously disclose the postponement of information disclosure.

2. Immediately after the state of force majeure has been remedied, the party subject to reporting and information disclosure shall be responsible for fully disclosing all information previously undisclosed in accordance with law.

Chapter II

INFORMATION DISCLOSURE ACTIVITIES ON THE CRYPTO-ASSET MARKET

Article 7. Information disclosure regarding the grant and revocation of the License for the provision of crypto-asset trading market organization services, and the selection of crypto-assets for admission to trading

1. The disclosure of information upon the grant or revocation of the License for the provision of crypto-asset trading market organization services shall be carried out in accordance with Clause 5, Article 10 and Clause 4, Article 12 of Resolution No. 05/2025/NQ-CP.

2. A crypto-asset service provider must disclose information on its website regarding the selection of crypto-assets for admission to trading at least 07 days prior to the official date of admitting the crypto-assets to trading.

3. In case of a decision to cancel or restrict the trading of crypto-assets, a crypto-asset service provider must disclose information on its website regarding the cancellation or restriction of trading of the crypto-assets at least 07 days prior to the official date of canceling or restricting the trading of such crypto-assets.

Article 8. Periodic information disclosure by crypto-asset service providers

1. A crypto-asset service provider must periodically disclose information on financial statements in accordance with Point a, Clause 3, Article 15 of Resolution No. 05/2025/NQ-CP.

2. The financial statements of a crypto-asset service provider shall be prepared in accordance with the law on accounting. In cases a crypto-asset service provider is a parent company, the crypto-asset service provider must disclose information on the financial statements of the parent company and the consolidated financial statements.

3. Auditing organizations and auditors carrying out audits and reviews of the financial statements of a crypto-asset service provider must be auditing organizations and auditors approved to carry out audits for public-interest entities in the securities sector in accordance with the law on auditing.

Article 9. Extraordinary information disclosure, information disclosure upon request, and information disclosure regarding amendments and supplements to procedures of crypto-asset service providers

1. A crypto-asset service provider shall disclose extraordinary information in accordance with Point b, Clause 3, Article 15 of Resolution No. 05/2025/NQ-CP.

2. A crypto-asset service provider shall disclose information upon request in accordance with Point c, Clause 3, Article 15 of Resolution No. 05/2025/NQ-CP.

3. In case of amending or supplementing the procedures prescribed at Points b, c, d, g, and k, Clause 6, Article 8 of Resolution No. 05/2025/NQ-CP, a crypto-asset service provider must publish the amended and supplemented procedures on its website within 24 hours from the time of issuance.

Article 10. Information on crypto-asset transactions at crypto-asset service providers

1. During trading hours, a crypto-asset service provider must publicly disclose on its website the following information on crypto-asset transactions:

a) Total number of types of crypto-assets permitted for trading; status of each type of crypto-asset;

b) Executed crypto-asset price and executed volume of the most recent transaction; highest trading price and lowest trading price during the trading day; price change level and symbol of each type of crypto-asset;

c) At least the three best bid and ask prices projected to remain after order matching, accompanied by the buy and sell order volumes projected to remain after order matching corresponding to such price levels;

d) Buy and sell trading values of foreign investors for each type of crypto-asset.

2. On a daily basis, a crypto-asset service provider must disclose information on crypto-asset trading of the immediately preceding trading day as follows:

a) Total number of types of crypto-assets permitted for trading during the day;

b) Price fluctuation range of crypto-assets during the trading day;

c) Number of orders, buy and sell order volumes, and corresponding values for each type of crypto-asset;

d) Trading volume and value of each type of crypto-asset, including order-matching transactions and transactions executed via other methods (if any).

Article 11. Information disclosure by crypto-asset issuers

1. The disclosure of information by a crypto-asset issuer shall be carried out simultaneously on the website of the crypto-asset service provider and the website of the issuer.

2. Prior to carrying out an offering and issuance, a crypto-asset issuer must disclose information on the prospectus for the offering and issuance of crypto-assets in accordance with Clause 3, Article 6 of Resolution No. 05/2025/NQ-CP.

3. In case of amending or supplementing information in the prospectus, the issuer must disclose information regarding such amendments and supplements within 24 hours from the time the prospectus is amended or supplemented.

4. Within 07 days from the completion date of a crypto-asset offering and issuance tranche, the issuer shall disclose information on the notice of results of the crypto-asset offering and issuance in accordance with the form prescribed in Appendix I issued together with this Circular.

5. In case of a decision to change the conditions or characteristics of issued crypto-assets, within 24 hours from the issuance of the decision on such change, the issuer must disclose information regarding the decision on the change.

6. Periodically every 06 months from the completion date of a crypto-asset offering and issuance tranche until the full fulfillment of all commitments to investors stated in the prospectus (if any), the crypto-asset issuer must disclose information on the progress of fulfilling such commitments.

7. Other information disclosures shall be carried out in accordance with the conditions stated in the prospectus.

Chapter III

REPORTING ACTIVITIES ON THE CRYPTO-ASSET MARKET

Article 12. Reporting on the maintenance of conditions for the grant of the License for the provision of crypto-asset trading market organization services

1. Periodically on the 10^th day of each month, a crypto-asset service provider shall report to the State Securities Commission on the list of shareholders and capital-contributing members being organizations compiled as of the 1^st day of that month in accordance with the form prescribed in Appendix II issued together with this Circular.

2. Within 05 days from the date of any change of the General Director (Director), change of the Chief Technology Officer (or equivalent position), reduction in personnel working in the technology department, or reduction in personnel holding securities practicing certificates working in other professional departments, a crypto-asset service provider shall report to the State Securities Commission on the personnel change, including an assessment of the maintenance of conditions for the grant of the License prescribed in Clause 5, Article 8 of Resolution No. 05/2025/NQ-CP.

3. Periodically on January 10 of each year, a crypto-asset service provider shall report to the State Securities Commission on the situation of personnel working in the technology department and personnel holding securities practicing certificates working in other professional departments in the immediately preceding year in accordance with the form prescribed in Appendix III issued together with this Circular.

4. At least 15 days prior to the date of carrying out an increase or decrease in charter capital under a decision of the competent authority of the company, a crypto-asset service provider must report to the State Securities Commission on the decision approving the plan to increase or decrease the company's charter capital.

Article 13. Reporting on crypto-asset trading organization activities

1. A crypto-asset service provider must report on the selection of crypto-assets for admission to trading in accordance with Point k, Clause 2, Article 15 of Resolution No. 05/2025/NQ-CP.

2. By no later than 15:00 daily, a crypto-asset service provider shall report to the State Securities Commission on crypto-asset trading activities of the immediately preceding trading day in accordance with the form prescribed in Appendix IV issued together with this Circular.

3. Periodically on the 10^th day of each month, a crypto-asset service provider shall report to the State Securities Commission on the situation of the crypto-asset trading market in the immediately preceding month in accordance with the form prescribed in Appendix V issued together with this Circular, and simultaneously provide information to the Ministry of Public Security and the State Bank of Vietnam in accordance with Point d, Clause 2, Article 15 of Resolution No. 05/2025/NQ-CP.

4. Periodically on the 10^th day of each month, a crypto-asset service provider shall report to the State Securities Commission on transactions showing signs of violation regarding crypto-asset trading under the surveillance procedures of the crypto-asset service provider that were handled in the immediately preceding month in accordance with the form prescribed in Appendix VI issued together with this Circular.

Article 14. Reporting on crypto-asset depository activities

1. Periodically on Monday of each week, a crypto-asset service provider shall report to the State Securities Commission data regarding crypto-asset depository in the immediately preceding week in accordance with the form prescribed in Appendix VII issued together with this Circular.

2. Except in the case of handling system incidents in accordance with disclosed procedures, a crypto-asset service provider must report to the State Securities Commission prior to changing system operations that affect the segregation of client assets or the asset allocation mechanism between hot wallets and cold wallets in accordance with the form prescribed in Appendix VIII issued together with this Circular.

3. In case of using the crypto-asset depository services of another crypto-asset service provider, at least 07 days prior to the date of using such services, the crypto-asset service provider shall report to the State Securities Commission in accordance with the form prescribed in Appendix IX issued together with this Circular.

4. A crypto-asset service provider shall report to the State Securities Commission on aggregated information on client assets for the reporting period from January 01 to June 30 and the reporting period from July 01 to December 31 in accordance with the form prescribed in Appendix X issued together with this Circular within 60 days from the end date of the reporting period.

Article 15. Reporting on crypto-asset proprietary trading activities

Periodically on the 10^th day of each month, a crypto-asset service provider shall report to the State Securities Commission on proprietary trading activities in the immediately preceding month in accordance with the form prescribed in Appendix XI issued together with this Circular

Article 16. Reporting on activities of providing a crypto-asset issuance platform

1. Periodically on the 10^th day of each month, a crypto-asset service provider shall report to the State Securities Commission on information regarding crypto-asset issuance tranches in the immediately preceding month in accordance with the form prescribed in Appendix XII issued together with this Circular, and simultaneously provide information to the Ministry of Public Security and the State Bank of Vietnam in accordance with Point c, Clause 2, Article 15 of Resolution No. 05/2025/NQ-CP.

2. Periodically on the 10^th day of each month, a crypto-asset service provider shall report to the State Securities Commission on the depository situation of crypto-assets issued through crypto-asset service providers licensed by the Ministry of Finance in accordance with the form prescribed in Appendix XIII issued together with this Circular

Article 17. Other reporting obligations of crypto-asset service providers

1. Within 24 hours from the detection of an information technology incident affecting the execution of crypto-asset transactions for clients, a crypto-asset service provider shall report to the State Securities Commission on the incident, including a description of the incident and the remedial plan.

2. By no later than March 31 of each year, a crypto-asset service provider shall report to the State Securities Commission on the compliance assessment of the crypto-asset service provider in the immediately preceding year in accordance with the form prescribed in Appendix XIV issued together with this Circular. The assessment of compliance with reporting obligations for tax administration purposes shall be carried out in accordance with the law on tax administration

Article 18. Reporting by other organizations and individuals

1. At least 03 days prior to the date of executing a transaction of a type of crypto-asset on the list of crypto-assets admitted to trading at a crypto-asset service provider, members of the Board of Directors or members of the Members' Council, the General Director, the Chief Technology Officer of the crypto-asset service provider, and their related persons as prescribed by the Law on Enterprises must report to the crypto-asset service provider on the crypto-asset transaction, clearly stating the quantity of crypto-assets, expected time, and expected method of transaction.

2. At least 07 days prior to the date of repurchasing issued crypto-assets, a crypto-asset issuer must report to the crypto-asset service provider where the crypto-assets are deposited on the repurchase of the crypto-assets.

3. Banks and foreign bank branches where foreign investors open specialized accounts must report on the aggregation of situation of receipts and disbursements on the specialized accounts for executing buy and sell transactions of crypto-assets by foreign investors in accordance with Clause 9, Article 13 of Resolution No. 05/2025/NQ-CP

Chapter IV

IMPLEMENTATION PROVISIONS

Article 19. Effect and organization of implementation

1. This Circular takes effect on December 18, 2026.

2. The State Securities Commission, crypto-asset service providers, and other relevant agencies, organizations, and individuals shall be responsible for implementing this Circular./.

* All Appendices are not translated herein.