Amidst the rapidly transforming global digital economy, Vietnam has taken a groundbreaking step by officially issuing a preliminary legal framework for accounting for digital assets. On March 4, 2026, the Ministry of Finance issued this framework. Circular No. 15/2026/TT-BTCThis establishes a dedicated accounting system for cryptocurrency business operations. This is considered a "guiding principle" for businesses, financial institutions, and investors in increasing transparency in blockchain and cryptocurrency-related transactions in Vietnam.
Overview of Circular 15/2026/TT-BTC and its context of issuance.
2026 marks a significant milestone as Vietnam implements a controlled pilot phase for virtual assets. Prior to this, the lack of a dedicated accounting system for cryptocurrency trading has caused considerable confusion for the finance department in recording assets, revenue, and expenses.
Strategic objectives
Circular 15/2026/TT-BTC was issued not only to standardize accounting records but also to serve macroeconomic objectives:
- Promoting the digital economy: Creating a safe legal environment for Fintech businesses to thrive.
- Anti-Money Laundering (AML): Closely monitor cryptocurrency flows according to FATF standards.
- Protecting investor rights: Ensuring that exchanges are transparent and open about their financial capacity and deposited assets.
Scope and duration of application
It should be noted that the accounting regime specifically for cryptocurrency trading activities under Circular 15 only applies to accounting purposes and the preparation of financial statements. This Circular does not apply to determining direct tax obligations (such as corporate income tax or value-added tax), which will be guided by separate documents from the General Department of Taxation.
The regulations will take effect starting from fiscal year 2026 and will last until new regulations replace them or the pilot phase ends.
The entities subject to the new accounting system.
Circular 15/2026/TT-BTC clearly categorizes three groups of entities that are required to comply with the accounting regime specifically for cryptocurrency business activities:
- VASP (Virtual Asset Service Providers): Units that provide services such as centralized exchanges (CEXs), custody platforms (Custody), and crypto payment gateways.
- Issuers: Businesses that raise capital through initial coin offerings (ICOs), issuing digital assets pegged to physical assets (RWA), or utility tokens.
- Institutional investors: Investment funds, finance companies, or businesses that allocate budgets to invest in crypto assets as part of their financial asset portfolio.
The core principles of accounting practices specifically for cryptocurrency trading.
Implementing a specific accounting regime for cryptocurrency trading requires a seamless integration of current Vietnamese Accounting Standards (VAS) and the technical characteristics of Blockchain.
The principle of "Substance over form"
This is the most important principle. Accountants shouldn't just look at the name of a token, but must analyze its economic nature. If a token grants the right to receive dividends, it is accounted for as a security. If it only serves the purpose of using a service, it is a type of upfront cost or intangible asset.
Absolute separation of client assets
The accounting system specifically designed for cryptocurrency trading requires separate ledgers for the company's own assets and customer assets held on the exchange. Customer assets are not recorded on the company's balance sheet to prevent capital tie-up.
Determine the exchange rate and currency unit.
Crypto assets are denominated in Vietnamese Dong (VND). The exchange rate is determined based on:
- The average price on major exchanges with high liquidity at the time the transaction occurs.
- The reference exchange rate is sourced from reputable data providers recognized by the Ministry of Finance.
Detailed accounting guidelines according to Circular 15/2026/TT-BTC
To effectively implement the accounting regime specifically for cryptocurrency business activities, organizations need to base their accounting methods on their specific role in the ecosystem. Depending on whether the entity is a service infrastructure provider, a direct issuer, or an asset holder for investment purposes, Circular 15/2026/TT-BTC provides specific operational guidelines to accurately reflect the nature of cash flows and assets as follows:
Group 1: Service Providers
In the accounting regime specifically for cryptocurrency trading activities, VASP entities need to pay particular attention to the following:
- Revenue Recognition: Revenue from trading fees is recorded in Account 511 (Revenue from sales and services) as soon as the transaction is successfully executed. Crypto fees must be converted to VND at the prevailing exchange rate at that time.
- Tracking held-in assets: Customer assets are tracked in off-balance sheet accounts (similar to Account 002 – Materials, goods held in custody, processing). However, the entity must provide detailed disclosures in the financial statements regarding the quantity, type, and market value of these assets.
- Proprietary trading: When the exchange buys and sells crypto assets to make a profit, this transaction is accounted for similarly to trading securities (Account 121). At the end of the period, the exchange must reassess the value and make a provision for impairment of investment in Account 229 if the market price is lower than the book value.
Group 2: Issuers of crypto assets
The issuer's accounting depends on their commitment to the token holder:
- Capital raising (Debt nature): If a business issues tokens and commits to repurchasing them or paying fixed interest, the proceeds must be accounted for in Account 341 (Loans and financial lease liabilities).
- Issuing Utility Tokens: The proceeds are typically recorded in Account 3387 (Unearned Revenue) and gradually allocated to revenue as users use the Tokens to exchange for the business's services.
- Issuance costs: Costs such as smart contract audit fees, marketing fees, and listing fees are aggregated into prepaid expenses (Account 242) and allocated appropriately over the project's expected duration.
Group 3: Institutional investors (Businesses, Investment funds)
The accounting system specifically for cryptocurrency trading classifies investment activities by purpose:
- Short-term investments (Swing trading): Accounted for in the Financial Assets group and recognized through profit/loss. Any price fluctuations directly affect the business results for the period.
- Long-term investment (Holding): Accounting is similar to investing in subsidiaries, associates, or other long-term investments depending on the voting rights ratio (if the Token has governance functions).
- Handling Gas Fees: Gas fees (Blockchain network fees) when transferring assets are usually added directly to the cost basis of the asset upon purchase or recorded as financial expenses (Account 635) upon sale.
Risks and challenges when implementing Crypto accounting in 2026
Despite having dedicated accounting systems for cryptocurrency trading, chief accountants still face unprecedented challenges.
Accounting documents in a Blockchain environment
Documents are no longer traditional paper invoices. According to Circular 15, electronic evidence such as transaction codes (TxID), Explorer screenshots, and wallet balance reconciliations are accepted as valid documents, but they must ensure integrity and cannot be altered or erased.
Cybersecurity risks
If a company's private key is hacked, how should accountants handle it? The regulations require recording an unusual asset loss (Account 811) only after receiving confirmation from the relevant authorities or technical department. This places significant pressure on internal control systems.
Extreme price volatility
In a single day, asset values can halve or double. Applying the closing price of December 31st to financial statements may not accurately reflect the company's financial picture just a few days later. Therefore, disclosing market risk is a mandatory requirement in the accounting regime specifically for cryptocurrency trading.
The Relationship Between Accounting and Tax Obligations 2026
A common mistake is equating accounting and tax filing. According to the spirit of Circular 15/2026/TT-BTC:
A common mistake is equating accounting and tax filing. According to the spirit of Circular 15/2026/TT-BTC:
- Accountant: To accurately reflect the asset situation.
- Tax: Taxes will be calculated based on actual (realized) revenue and profit. However, to optimize costs and ensure compliance, businesses should consult with relevant authorities. tax accounting services Professionals are needed to handle discrepancies between accounting profit and taxable profit.
For example: An "unrealized" profit due to the increase in token price may be recorded in accounting but may not necessarily be subject to income tax until the business sells (takes profit) it in fiat currency (VND).
Recommendations for businesses trading in crypto assets.
To comply with the accounting regulations specifically for cryptocurrency trading, businesses need to take the following steps immediately:
- Upgrade your accounting software: Use software that supports direct connection to exchange APIs or blockchain tracking tools (such as Chainalysis, Nansen) to automate transaction data retrieval.
- Training staff or outsourcing experts: Accountants in 2026 will not only need to be proficient in debit and credit accounting, but also understand e-wallets and smart contracts. If internal resources cannot meet the complexity of the crypto field, then hiring external experts is a viable option. accounting services by industry This will be the optimal solution to help businesses handle specific tasks accurately.
- Establish wallet control procedures: Clearly define who holds the key, and implement a multi-signature process for approving large asset transfers.
Conclude
The issuance of a specific accounting regime for cryptocurrency business activities through Circular 15/2026/TT-BTC is a progressive step forward for Vietnam's financial sector. It not only helps businesses be more confident in their financial reporting but also lays the groundwork for international organizations to view the Vietnamese market as a transparent and promising destination for digital capital.
Although still in the pilot phase, mastering these accounting principles will help businesses gain an advantage, avoid legal risks, and prepare for the explosion of cryptocurrency assets in the near future.
Contact information MAN – Master Accountant Network
- Address: No. 19A, Street 43, Tan Thuan Ward, Ho Chi Minh City
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- Email: man@man.net.vn
Content production by: Mr. Le Hoang Tuyen – Founder & CEO of MAN – Master Accountant NetworkCPA Vietnam auditors with over 30 years of experience in accounting, auditing, and financial consulting.h.
Source: Article by LuatVietnam
Frequently Asked Questions about Accounting Regimes Specific to Crypto Assets
No. Circular 15/2026/TT-BTC only applies to organizations and businesses. Individuals are still subject to personal income tax regulations (if further guidance is provided).
In Vietnam, crypto assets are not considered currency or legal tender. Circular 15 only provides guidance on accounting for them as a type of asset (similar to goods or securities). Do individuals engaged in crypto trading have to comply with Circular 15?
Are cryptocurrencies considered currency?
