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Step 1
Make the marinade: In large bowl, combine the vegetable oil, fish sauce, brown sugar, rice vinegar, garlic and black pepper. Set aside.
Step 2
Rinse the chicken and pat it dry. Add the chicken to the marinade and gently toss the chicken in to get it coated evenly. Marinate the chicken for at least 1 hour (2-3 hours preferred) so the chicken can soak up all the flavor. Gently stir up the chicken in the marinade at least twice during the 1-3 hours so that all the pieces of chicken get an even soak in the marinade.
Step 3
Make the flour coating: In a large bowl, combine the flour and baking powder. Slowly add the cold water and whisk to combine. Start with about 1.5 cups and add more if needed. Break up any clumps of flour so that the mixture is smooth. What you want to get is a thick and moist flour mixture that will cling to the chicken. Please see reference photo on the post.
Step 4
Heat a large frying pan or Dutch oven. Fill the pan or Dutch oven with oil about 1-inch deep. Heat the oil to 350-375°F.
Step 5
Gently remove the chicken from the marinade and let the excess drip off. Dip the chicken in to the wet flour mixture. Allow excess to drip off and place the chicken in the hot oil.
Step 6
Cooking in small batches, fry the chicken on both sides until crispy and cooked through, about 10-15 minutes. Don't crowd the chicken.
Step 7
Garnish with minced cilantro (optional). Serve warm with hot sauce and/or rice.