In the context of the rapidly shifting global digital economy, managing and accounting for new asset classes such as crypto assets has become a pressing requirement. On March 4, 2026, the Ministry of Finance officially issued regulations on this matter. Circular 15/2026/TT-BTC This document aims to guide accounting principles for organizations participating in the cryptocurrency market in Vietnam. It is considered a foundational legal document, helping businesses and financial institutions standardize their bookkeeping and financial reporting processes during this crucial pilot phase.
Overview of Circular 15/2026/TT-BTC
The issuance of Circular 15/2026/TT-BTC is not accidental but the result of a thorough preparation process by the Government and the Ministry of Finance. This document specifies the contents stipulated in Resolution No. 05/2025/NQ-CP dated September 9, 2025, on the pilot implementation of the cryptocurrency market in Vietnam.
Key legal information:
- Circular No.: 15/2026/TT-BTC
- Date of issue: March 4, 2026
- Issuing authority: Ministry of Finance
- Signed by: Deputy Minister Nguyen Duc Tam
- Effective date: This Circular takes effect from the date of signing (March 4, 2026) and will immediately apply to the 2026 accounting year.
The issuance of Circular 15/2026/TT-BTC is based on important grounds such as:
- Accounting Law No. 88/2015/QH13 (amended by Law No. 56/2024/QH15).
- Law on Industry and Technology No. 71/2025/QH15.
- Resolution No. 57-NQ/TW dated December 22, 2024, on breakthroughs in national science, technology development and digital transformation.
Scope of regulation and subjects of application as per Circular 15/2026/TT-BTC
One of the first points to note is the scope of this document. Circular 15/2026/TT-BTC focuses on guiding the principles of accounting, bookkeeping, and presentation of financial statements.
Scope of regulation
Circular 15/2026/TT-BTC provides guidance on accounting principles for organizations participating in the market during the pilot implementation period. However, an important clause in Article 1 emphasizes that this Circular does not apply to determining the tax obligations of organizations to the State Budget. Businesses need to clearly distinguish between accounting and taxation to avoid errors during the year-end settlement process..
Applicable objects
This document is addressed to three main groups of entities established and operating under Vietnamese law:
- Cryptocurrency service providers (VASPs): These include exchanges (market organizations), cryptocurrency custodians, and platform issuers.
- Cryptocurrency issuers: Businesses that raise capital or issue digital assets (Tokens/Coins) to the market in accordance with Resolution 05/2025/NQ-CP.
- Domestic institutional investors: Investment funds, finance companies, or businesses that hold crypto assets as part of their financial investment portfolio.
General accounting principles under the new regulations
According to Article 4 of Circular 15/2026/TT-BTC, participating organizations must fully comply with the Accounting Law and the Enterprise Accounting System issued therewith. Circular No. 99/2025/TT-BTC October 27, 2025.
The principle of "Substance over Form" (Article 3) is a core principle emphasized by Circular 15/2026/TT-BTC. In cases where there are no specific regulations on technical terminology, accounting must be based on the economic substance of the transaction.
- If the crypto asset is of the nature of goods for sale: Accounting is similar to inventory.
- If the crypto asset is a financial instrument: Accounting is similar to that of trading securities or financial investments.
Detailed accounting guidelines for Vietnam Service Providers (VASPs)
For exchange and custody operators, Circular 15/2026/TT-BTC sets stringent requirements regarding transparency and asset segregation.
Record revenue (Account 511)
These organizations must record revenue from services in the "Revenue from Sales and Services Provided" account. Circular 15/2026/TT-BTC requires detailed tracking for each type:
- Market organizing services: Order execution fees, withdrawal/deposit fees.
- Custody service: Wallet management fee, cryptocurrency safekeeping fee.
- Issuance platform services: Listing fees, issuance advisory fees.
Separate asset management
This is the golden rule of Circular 15/2026/TT-BTC. Service providers must:
- Manage and account for client crypto assets separately from your own assets.
- Customer assets should not be recognized as assets of the organization on the Balance Sheet (except where there are other provisions regarding ownership).
- The detailed balances of each customer's assets must be tracked in the off-balance sheet ledger or intermediate account system as per operational regulations.
Accounts receivable management and provisions
The unit must classify and meticulously track accounts receivable arising from encryption service fees. Provisions for doubtful accounts receivable must be made periodically in accordance with financial laws to ensure capital safety.
Accounting for Issuers of Crypto Assets
When a business issues digital assets, Circular 15/2026/TT-BTC requires accounting based on the nature of the obligations arising from the token holders:
- In cases involving capital mobilization: If the issuing entity commits to repaying money or assets in the future (similar to borrowing), the organization must record it in the liabilities accounts (Account 331, 338, or 341 depending on the nature).
- In the case of exchanging tokens for future services: The proceeds from the sale of prepaid tokens will be accounted for as "Unearned Revenue" (Account 3387). This revenue will only be transferred to Account 511 when the actual service has been provided to the token holder.
- Issuance costs: Costs for system development, Smart Contracts, and legal consulting fees for issuance are aggregated into work-in-progress (Account 154) or prepaid expenses (Account 242) for allocation.
Guidelines for Institutional Investors
For businesses holding crypto assets as an investment, Circular 15/2026/TT-BTC provides accounting guidance similar to financial investment activities.
- Determining the original cost: At the time of purchase, the asset is recorded at its actual purchase price plus any related direct costs (exchange transaction fees).
- Classification by holding purpose: Short-term holding (less than 12 months) is accounted for in Account 121 – Trading Securities (Details of coded assets). Long-term holding must be accounted for in Account 228 – Other Investments.
- Revaluation at the time of preparing Financial Statements: Due to the extremely volatile nature of the cryptocurrency market, Circular 15/2026/TT-BTC requires entities to have reliable market evidence (prices from major exchanges licensed under the pilot program) to record provisions for impairment or revaluation of assets.
Analysis of the Impacts and Implementation Challenges of Circular 15/2026/TT-BTC
The issuance of Circular 15/2026/TT-BTC is not merely an addition to an accounting regulation, but also creates profound changes to the digital asset ecosystem in Vietnam. However, alongside the breakthrough opportunities for businesses, this document also poses many challenging problems in the practical implementation process. To better understand the overall picture, let's analyze both aspects thoroughly with MAN – Master Accountant Network:
- Positive values
- The technical barriers that accounting departments face.
Positive impact
The issuance of Circular 15/2026/TT-BTC brings three major benefits:
- Transparency: Eliminating "grey areas" in financial reporting helps regulatory agencies (State Bank of Vietnam, Ministry of Finance) monitor the flow of money in the pilot market.
- Attracting investment: International investment funds will feel more confident investing in Web3/Blockchain projects in Vietnam when there is a well-established accounting system.
- Reduced legal risk: Businesses have a basis to explain to authorities the source of funds and the legality of profits from Crypto.
Despite possessing clear advantages in terms of legal status and transparency, translating the regulations in Circular 15/2026/TT-BTC into accurate accounting entries is a challenging journey. The technical characteristics of Blockchain sometimes contradict traditional accounting methods, creating bottlenecks that businesses need to identify early on.
Challenges for the accounting department
Although Circular 15/2026/TT-BTC provides a framework of principles, its practical implementation will face difficulties due to:
- Determining Fair Value: The crypto market operates 24/7 across multiple international exchanges, and selecting the closing price at a given time for accounting purposes requires close agreement.
- Software system: Current accounting software needs to integrate the ability to reconcile with on-chain data to ensure accurate matching between the general ledger and the balance in the e-wallet.
Conclusion and recommendations
Circular 15/2026/TT-BTC serves as a guiding principle for the professionalization of the cryptocurrency market in Vietnam. Compliance with the circular is not only a legal obligation but also an opportunity for digital technology businesses to demonstrate transparency and financial capacity to major investors.
In this challenging digital transformation era, mastering new business rules is crucial for survival. To optimize processes and minimize the risk of errors, businesses should refer to the following: full accounting service To ensure that financial statements always strictly comply with the standards of Circular 15/2026/TT-BTC.
Advice for businesses:
- System upgrade: Update the accounting chart of accounts in accordance with the guidelines of Circular 15/2026/TT-BTC.
- Internal controls: Establish a transaction approval process on the business wallet equivalent to the process for approving bank deposits.
- Monitoring tax policies: Since Circular 15/2026/TT-BTC does not yet provide guidance on taxation, businesses need to keep separate accounting records to be prepared for the expected Crypto tax regulations that will be issued in the near future.
Complying with Circular 15/2026/TT-BTC starting in 2026 will help businesses take the lead in the digital finance era in Vietnam.
Contact Contact MAN – Master Accountant Network for advice and support!
Contact information MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
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Content production by: Mr. Le Hoang Tuyen – Founder & CEO MAN – Master Accountant Network, Vietnamese CPA Auditor with over 30 years of experience in Accounting, Auditing and Financial Consulting.
References:
- Circular 15/2026/TT-BTC
- Resolution No. 05/2025/NQ-CP
- Accounting Law No. 88/2015/QH13 and guiding documents.
Frequently Asked Questions about Circular 15/2026/TT-BTC
