ASSET NEWS VIETNAM | NOVEMBER 2–8, 2026 The most significant development this week is that the reporting and disclosure framework for the crypto asset market has moved from draft to officially issued regulation. 1. Issuance of Reporting and Disclosure Requirements - The State Securities Commission announced on November 3, 2026, Circular 165/2026/TT-BTC, signed on October 31, effective December 18, 2026. This is now an officially issued regulation awaiting its effective date, no longer a proposal. - Key obligations include: reporting technology incidents affecting trading within 24 hours; weekly reporting of custody data; and prior notification before operational changes that impact client asset segregation or hot/cold wallet allocation, except in cases of emergency response under published procedures. - Exchange executives and related parties must report trades at least three days in advance. => Impact: Exchange applicants must immediately begin preparing compliance schedules, designated personnel, custody data systems, and incident reporting procedures during the system design phase. *Note: Distinguish between regulatory reporting and public disclosure—reporting an incident to regulators within 24 hours does not automatically require full public disclosure of the incident. 2. Issuers Must Monitor Post-Issuance Commitments - The circular mandates disclosure of amended prospectuses and changes to asset conditions within 24 hours; publication of offering results within seven days; and periodic (every six months) updates on commitment fulfillment until completion. These obligations also take effect on December 18, 2026. => Impact: Crypto asset issuers must standardize commitments in their prospectuses, establish approval mechanisms for changes, and maintain documentation proving commitment fulfillment.信息披露 should not be treated as a one-time task limited to the issuance phase. *Key milestones to monitor: December 18 for implementation of Circular 165; first exchange licensing decision; additional tax guidance. Issuance of this circular does not imply that exchanges are licensed or that trading has commenced. *Conclusion: - Circular 165 marks the regulator’s move toward concrete operational requirements for the crypto asset market, moving beyond general legal principles. - For businesses preparing to enter the market, requirements for custody, security, transaction monitoring, and information reporting must be integrated from the earliest stages of system development.