For many years, Vietnam’s horse race betting industry resembled a race without a rulebook.
Investors were attracted by the prospect of participating in one of Asia’s fastest-growing economies, yet they faced a fundamental challenge: horse race betting had been permitted through limited pilot projects, but there was no comprehensive legal framework governing licensing, operation, investor qualifications, betting products or regulatory supervision.
That is no longer the case.
The legal landscape changed fundamentally with the issuance of Decree No. 06/2017/ND-CP on the Business of Betting on Horse Racing, Greyhound Racing and International Football, which established Vietnam’s first comprehensive regulatory framework governing licensed betting activities. The sector has therefore moved beyond the question of legalization and entered a new phase focused on implementation, compliance and commercial viability.
Yet nearly a decade after the issuance of Decree 06, the most important question for investors is no longer whether horse race betting is legal.
The real question is whether a particular business model can be structured, licensed and operated successfully within Vietnam’s evolving regulatory framework.
A Significant Shift in Regulatory Thinking
Vietnam has historically approached gambling and betting activities with considerable caution.
Unlike many jurisdictions that view betting primarily as a commercial entertainment activity, Vietnam continues to regulate betting through the dual lens of economic opportunity and social policy. Regulators seek to balance investment promotion, tax revenues, tourism development and employment generation against concerns relating to social order, responsible gaming, money laundering and consumer protection.
The result is a framework that permits betting, but only under tightly controlled conditions.
Decree 06 formally legalized horse race betting and greyhound race betting and introduced a pilot framework for international football betting. However, licensing is not automatic and betting remains subject to significant investment, operational and compliance requirements.
The Current Licensing Framework
One of the most important realities for prospective investors is that Vietnam does not currently permit a simple online horse betting operation.
The existing framework was designed around operators that develop and operate actual horse racing infrastructure and betting operations.
Under Decree 06, a horse race betting project must be approved by the competent authorities and satisfy a series of investment, operational and business-condition requirements before betting activities may commence.
The minimum investment requirement for a horse race betting project remains VND 1 trillion. In addition, investors must demonstrate:
- Adequate financial capability;
- Suitable racecourse and betting infrastructure;
- Appropriate technology systems;
- Internal control mechanisms;
- Anti-money laundering procedures;
- Responsible gaming measures;
- Security and public order safeguards; and
- Operational procedures compliant with Vietnamese law.
In practice, obtaining approvals requires interaction with multiple governmental authorities and remains one of the more heavily regulated investment sectors in Vietnam.
Why the Current Framework Is Under Review
Although Decree 06 represented a major regulatory breakthrough, implementation has been slower than many market participants anticipated.
Industry participants and policy experts have argued that certain provisions are overly restrictive and do not adequately reflect modern betting markets. As a result, the Ministry of Finance has been studying amendments and modernization measures intended to make the framework more commercially practical while maintaining appropriate governmental oversight.
Among the issues under consideration are:
- Expansion of permitted betting products;
- Greater use of foreign race results and data;
- Modernization of distribution channels;
- Enhanced compliance mechanisms;
- Improved monitoring and reporting systems; and
- Clarification of operational requirements that have proven difficult to implement in practice.
Investors should closely monitor future regulatory developments, as any amendments could materially affect the attractiveness and structure of future projects.
The Emerging Challenge: Technology, Digital Assets and Decentralized Betting
The most interesting legal questions today are no longer being asked solely by traditional racecourse operators.
Increasingly, entrepreneurs are exploring blockchain-based betting exchanges, prediction markets, stablecoin settlement systems, decentralized wagering platforms and other technology-driven business models.
These structures often seek to distinguish themselves from traditional betting operators by arguing that:
- They do not accept wagers directly;
- They do not hold customer funds;
- They merely provide software infrastructure;
- Betting occurs between participants rather than against a bookmaker; and
- Smart contracts execute settlements automatically.
However, investors should exercise caution before assuming that technological innovation automatically eliminates licensing requirements.
Vietnamese regulators are likely to examine the economic substance and practical operation of a project rather than relying solely on its technical architecture. If a platform facilitates wagering on race outcomes and generates revenue from betting-related activities, regulators may conclude that betting regulations, digital asset regulations, payment regulations, anti-money laundering rules, cybersecurity obligations and consumer protection requirements all become relevant.
This issue is particularly important given Vietnam’s rapidly evolving regulatory framework relating to digital assets and virtual asset activities.
Can a Horse Betting Business Be Established in Vietnam Today?
The short answer is yes—but only under the right structure, with the appropriate approvals and with realistic expectations regarding the regulatory process.
Unlike ten years ago, horse race betting is no longer operating in a legal vacuum. Vietnam now has a formal regulatory framework. Accordingly, the question is no longer whether horse race betting is legal in principle. The question is whether a particular business model can be structured and licensed in compliance with Vietnamese law.
Investors should be cautious about relying on theoretical legal interpretations or assumptions that a project falls outside the betting regulations because it uses technology, blockchain, smart contracts, digital assets or offshore structures.
Vietnamese authorities will generally examine the substance and economic reality of a project rather than merely its legal form.
The Importance of Regulatory Due Diligence and Government Engagement
Perhaps the most important lesson for investors is that betting projects should not be structured first and discussed with regulators later.
In Vietnam, successful projects in highly regulated sectors are generally built through active cooperation between investors, legal counsel and the relevant authorities from the earliest stages of development.
Investors should therefore view legal counsel not merely as a documentation provider, but as a strategic adviser responsible for conducting regulatory due diligence, identifying legal risks, developing licensing pathways and facilitating discussions with the competent authorities.
Depending on the specific structure of a proposed project, relevant authorities may include:
- Ministry of Finance;
- Ministry of Public Security;
- State Bank of Vietnam;
- Ministry of Science and Technology;
- Ministry of Culture, Sports and Tourism;
- Provincial People’s Committees;
- Tax authorities; and
- Other regulators depending on the specific business model.
Early consultation is particularly important because many practical questions may not be answered expressly by legislation and may require clarification through discussions with the authorities.
What Must Be Done to Establish a Compliant Horse Betting Business?
Although every project will have unique characteristics, investors should generally expect the following workstreams:
Phase 1 – Regulatory Feasibility Assessment
- Legal and regulatory due diligence;
- Analysis of the proposed business model;
- Review of ownership and investment structures;
- Assessment of foreign investment restrictions;
- Analysis of betting and gaming regulations;
- Review of technology and digital asset components;
- Identification of licensing pathways and regulatory risks.
Phase 2 – Regulatory Engagement
- Preliminary consultations with relevant authorities;
- Clarification of licensing requirements;
- Assessment of investment conditions;
- Review of operational requirements;
- Evaluation of compliance obligations.
Phase 3 – Investment Structuring
- Establishment of the investment structure;
- Foreign investment approvals;
- Corporate establishment;
- Capital contribution planning;
- Tax and financing structuring.
Phase 4 – Licensing and Implementation
- Investment approvals;
- Operational licenses and certifications;
- Preparation of betting rules and operating procedures;
- AML and KYC frameworks;
- Technology compliance reviews;
- Internal governance systems.
Phase 5 – Ongoing Compliance
- Regulatory reporting;
- Internal audits and controls;
- Data protection compliance;
- AML monitoring;
- Continuous regulatory monitoring.
Strategic Lessons for Investors
The greatest mistake investors can make is to focus exclusively on whether betting is technically legal.
Successful projects in Vietnam are rarely determined by a single legal provision.
Instead, success depends on understanding the broader regulatory ecosystem, including investment approvals, licensing requirements, taxation, anti-money laundering compliance, technology regulation, cybersecurity obligations and governmental expectations.
Investors should therefore ask:
- Is the proposed model consistent with the current licensing framework?
- Does the project require racecourse infrastructure?
- Can the applicable investment thresholds be satisfied?
- Will regulators view the activity as betting, software, fintech or some combination of all three?
- Does the business involve digital assets or stablecoins?
- Are foreign race data and betting products involved?
- Can the structure withstand future regulatory scrutiny as the legal framework evolves?
These questions should be answered before substantial capital is committed.
Conclusion: Opportunity Exists, But Preparation Wins the Race
Vietnam’s horse race betting market has come a long way from the days of regulatory uncertainty.
The industry now benefits from a formal legal framework, defined licensing procedures and increasing regulatory experience. At the same time, policymakers continue to evaluate reforms intended to modernize the sector and improve commercial viability.
For investors, this creates both opportunity and risk.
The opportunity lies in entering a market that remains relatively underdeveloped but offers significant long-term potential. The risk lies in underestimating the complexity of the regulatory environment or assuming that innovative technology alone can overcome legal requirements.
As in horse racing itself, success rarely belongs to the fastest starter.
It belongs to the participant who understands the track, studies the conditions and prepares for the entire race.
In Vietnam’s horse race betting sector, thorough legal due diligence, proactive engagement with regulators and careful investment structuring remain the most reliable path from regulatory approval to commercial reality.
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For more information on the above, please do not hesitate to contact the author Dr. Oliver Massmann under [email protected]. Dr. Oliver Massmann is the General Director of Duane Morris Vietnam LLC.