Vietnam has two compulsory climate reporting rules: public companies publish environmental figures, including total greenhouse gas emissions, in their annual report, and 2,441 large factories, power plants, buildings, transport firms and waste sites submit a detailed emissions inventory to the government.
The emissions inventory is due every two years, before 31 March, and the next one covers 2025 and 2026 and is due before 31 March 2027.
110 power, steel and cement plants hold emissions allowances in a pilot carbon market, and must have their inventory checked by an independent verifier. A national carbon exchange opened in June 2026.
The Ministry of Finance consulted until 7 October 2026 on a new rule that would require every public company to publish a sustainability report and say why it leaves out any figure. The start date is still to be set.
| Regulator | Annual report rule: Ministry of Finance and the State Securities Commission. Facility inventory and carbon market: Ministry of Agriculture and Environment, with the Ministries of Industry and Trade and of Construction, and provincial People's Committees |
| Standard | Circular 96/2020/TT-BTC, Appendix IV (annual report environmental and social section). Decree 06/2022/ND-CP as amended by Decree 119/2025/ND-CP (facility greenhouse gas inventory and carbon market). Draft circular replacing Circular 96 (proposed) |
| Companies in scope | Annual report rule: every public company under the Law on Securities 2019. Facility inventory: facilities emitting 3,000 tCO2e or more a year, or above energy and waste thresholds, named in Decision 42/2026/QD-TTg |
| Estimated population | 2,441 facilities on the Decision 42/2026/QD-TTg list, of which 110 hold pilot allowances. Public companies: not specified in the rule |
| First reporting year | Annual reports for financial years from 2021 (Circular 96 in force 1 January 2021). Facility inventories from the 2024 data year, first due before 31 March 2025, then every two years |
| Scope 3 required | No. The annual report covers total direct and indirect emissions; facility inventories cover direct emissions plus purchased electricity and steam |
| Assurance | Annual report rule: not specified in the rule. Facility inventory: verification by a registered conformity assessment body for allowance-holding facilities, verified reports due to the Ministry of Agriculture and Environment before 1 December, from 2027; provincial review for all other facilities |
| Penalty regime | Decree 45/2022/ND-CP: a warning for failing to submit a facility inventory, VND 30 million to 50 million for failing to prepare one (individuals; organisations pay double). Annual report breaches fall under Decree 156/2020/ND-CP on securities sanctions |
Vietnam requires climate reporting under two rules: Ministry of Finance Circular 96/2020/TT-BTC, in force since 1 January 2021, requires every public company to report total direct and indirect greenhouse gas emissions, energy and water use in its annual report, and Decree 06/2022/ND-CP, amended by Decree 119/2025/ND-CP from 1 August 2025, requires 2,441 high-emitting facilities to submit a greenhouse gas inventory every two years. On 25 September 2026 the Ministry of Finance published a draft circular that would replace Circular 96 with a disclose-or-explain sustainability report for public companies (proposed; consultation closed 7 October 2026), and 110 thermal power, steel and cement plants trade allowances in a pilot emissions trading system.
Circular 96/2020/TT-BTC added an environmental and social section to every public company's annual report from 1 January 2021. The Law on Environmental Protection 2020 set the legal base for the facility track, and Decree 06/2022/ND-CP of 7 January 2022 turned it into a facility inventory and a carbon market roadmap. Decision 232/QD-TTg of 24 January 2025 approved the carbon market scheme, with a pilot to the end of 2028 and an official market from 2029.
Decree 119/2025/ND-CP, issued on 9 June 2025 and in force from 1 August 2025, moved inventories to a two-year cycle, added verification for allowance-holding facilities and set the rules for allocating allowances. Decision 263/QD-TTg of 9 February 2026 gave 110 plants their first allowances for 2025 and 2026, and the domestic carbon exchange at the Hanoi Stock Exchange started operating on 29 June 2026. Decision 42/2026/QD-TTg, in force from 25 September 2026, replaced the facility list with 2,441 facilities.
Public companies report headline environmental figures every year, and listed facilities report a full greenhouse gas inventory every two years.
Annual report environmental and social section (Circular 96, Appendix IV, item 6): total direct and indirect greenhouse gas emissions and the measures to reduce them; raw materials used and the share recycled; direct and indirect energy consumption and energy saved; water use and the share recycled; and environmental fines. Companies can publish the section as a separate sustainability development report. Finance, banking, securities and insurance companies are exempt from the emissions, materials and energy items. The circular encourages "globally accepted reporting and disclosure standards" and names none.
Facility greenhouse gas inventory (Decree 06, Article 11): each listed facility submits an inventory report to its provincial People's Committee before 31 March, every two years, covering the two years before submission. The province reviews it and forwards it to the Ministry of Agriculture and Environment and the sector ministry before 30 June. Under the Ministry of Industry and Trade's sector rules (Circular 38/2023/TT-BCT), the inventory covers combustion, process, fugitive, refrigerant and waste emissions, plus purchased electricity and steam.
Mitigation and allowances: facilities without allowances submitted a 2026 to 2030 mitigation plan before 31 December 2025 and report on it every year before 31 March, from 2027. Allowance-holding facilities surrender allowances against their direct emissions by 31 December of the year after each period, and can cover up to 30 per cent with carbon credits.
Draft disclosure circular (proposed): Article 10(5) requires public companies to publish sustainability information, covering environmental, social and governance indicators on a new Appendix V template, at the same time as the annual report. A company discloses every indicator it can determine and measure, and for any indicator it omits, gives the reason and a plan and timeline to disclose it. The effective date is blank in the draft.
Measurement method: facility inventories follow the IPCC guidelines, and Decree 06 requires the sector methods issued by the ministries to be consistent with the GHG Protocol.
Every public company reports in its annual report, and every facility named on the national list prepares an inventory.
Public companies: joint-stock companies that meet the public company definition in Article 32 of the Law on Securities 2019, which includes every company listed on Vietnam's stock exchanges and every company that has made an initial public offering registered with the State Securities Commission.
Facilities on the national list: Decree 06 Article 6 sets the criteria: annual emissions of 3,000 tCO2e or more, or annual energy use of 1,000 tonnes of oil equivalent or more for thermal power plants, industrial facilities, freight transport companies and commercial buildings, or 65,000 tonnes a year or more for solid waste facilities. Decision 42/2026/QD-TTg names 2,441 facilities: 1,916 under the Ministry of Industry and Trade, 411 under the Ministry of Construction, 53 in transport and 61 under the Ministry of Agriculture and Environment. The list is updated every two years.
Pilot carbon market: 110 facilities hold allowances for 2025 and 2026: 34 thermal power plants, 25 steel plants and 51 cement plants, under total caps of 243,082,392 tCO2e for 2025 and 268,391,454 tCO2e for 2026.
Supply-chain reach: Vietnamese manufacturers and exporters supply companies that report Scope 3 under ISSB-based rules in Japan, Korea, Singapore and Australia, and under the EU's sustainability reporting standards. Those buyers request supplier emissions data on top of what Vietnamese law requires.
Note on financial institutions: State Bank of Vietnam Circular 17/2022/TT-NHNN, in force from 1 June 2023, requires credit institutions to assess environmental risk before lending to specified project types.
| Milestone | Measurement year | First reporting date |
| Circular 96: environmental and social section in annual reports | Financial years from 2021 | Within 20 days of the audited financial statements, no later than 110 days after year-end |
| Decree 06 issued; first facility list (1,912 facilities) | 2022 | 7 January 2022 |
| First facility inventory reports | 2024 | Before 31 March 2025 |
| Carbon market scheme approved (Decision 232) | Pilot to 2028, official market from 2029 | 24 January 2025 |
| Decree 119/2025: two-year cycle, verification, allowances | Current regime | In force 1 August 2025 |
| Facility mitigation plans (facilities without allowances) | 2026 to 2030 | Before 31 December 2025 |
| First allowances for 110 plants (Decision 263) | 2025 and 2026 | 9 February 2026 |
| Domestic carbon exchange opens at the Hanoi Stock Exchange | Current regime | 29 June 2026 |
| Updated list of 2,441 facilities (Decision 42) | Current regime | In force 25 September 2026 |
| Draft circular replacing Circular 96 (proposed) | Effective date: not yet published | Consultation closed 7 October 2026 |
| Next facility inventory reports | 2025 and 2026 | Before 31 March 2027 |
| Verified inventories of allowance-holding facilities | From 2027 | Before 1 December 2027 |
| Allowance surrender for the first pilot period | 2025 and 2026 | 31 December 2027 |
Allowances for 2027 and 2028 are due to be allocated by 31 October 2027. Facilities removed from the list in September 2026 stop reporting from the 2026 data year.
1. Export supply chains face EU border and product rules. The EU Carbon Border Adjustment Mechanism, in its definitive period since 1 January 2026, prices embedded emissions in imported steel, cement, aluminium, fertilisers, electricity and hydrogen, the sectors at the centre of Vietnam's pilot carbon market. The EU Deforestation Regulation applies from 30 December 2026 to coffee, rubber, wood and other commodities Vietnam exports. Both run on supplier-specific data, the same data a Scope 3 supplier engagement programme collects.
2. Convergence with the region. Singapore, Malaysia, Japan, Korea and Australia have built disclosure rules on IFRS S2. Vietnam's draft circular moves public companies from a short annual report section to a full sustainability report with disclose-or-explain, and a corporate carbon footprint built on the GHG Protocol serves both the domestic report and buyers' ISSB-based requests.
3. A carbon price is arriving. Pilot allowances for 110 plants, a live exchange and auctions from 2029 put a price on verified emissions data. Installations need inventory figures that reconcile from meter to allowance, including energy, waste and water data.
The next facility inventory covers 2025 and 2026, so the data for it is being collected now.
Establish your greenhouse gas inventory on the GHG Protocol. Scope 1 and Scope 2 by facility, measured on IPCC methods consistent with the GHG Protocol, meet the Decree 06 inventory and feed the annual report's total emissions figure.
Map your value-chain exposure. Identify which customers report Scope 3 or import into the EU under the border mechanism or the deforestation rules, and which of your products and sites they ask about.
Build assurance-ready processes early. Allowance-holding plants face independent verification from 2027, and every other facility faces provincial review. Methodology documentation, source-data traceability and review controls need to be in place during measurement, so every figure answers the verifier's question: where did this number come from?
Build on the frameworks you already use. Companies that already publish the Circular 96 section, respond to CDP or answer buyer questionnaires hold much of the data. The new work under the draft circular is a full indicator set, with a reasoned plan for every gap.
Terrascope's AI-powered platform helps companies operating in Southeast Asia move from baseline emissions data to audit-ready disclosures, including Greenfields, one of Southeast Asia's largest dairy companies, which built a Scope 1, 2 and 3 baseline across feed, farms, manufacturing and distribution and uncovered the potential to reduce cattle feed emissions by more than 50 per cent.
Scope 1, 2, and 3 emissions measurement. Integrations pull emissions data from your source systems monthly, so each listed facility's inventory stays current across the two-year cycle.
Audit-ready reporting. Audit Trail makes every figure traceable from data entry to disclosure, with verifier access built in, so your inventory is ready for provincial review or third-party verification.
Supply-chain intelligence. Analytics shows you where your emissions hotspots sit, so buyer requests, border-rule declarations and your Decree 06 inventory draw on one dataset.
Multi-framework alignment (Climate reporting). ISSB Reporting drafts your disclosures from your measured data, reviewed by your team, ready for the annual report today and the full sustainability report the draft circular proposes.
Are you ready to get ahead of Vietnam's greenhouse gas inventory and disclosure requirements? Speak to a Terrascope expert and see how we help companies move from baseline emissions data to audit-ready disclosures.