Vietnam

Yes. ESG disclosures are governed by legislation applicable to specific regimes, principally environmental laws and corporate governance laws.

Circular 96 requires that certain companies make public disclosures in respect of the environment and society, including in connection with GHG emissions, resource management, energy consumption, water consumption, compliance with laws on environmental protection, policies related to employees and responsibility to the local community.^[1] These disclosures are essentially imposed on public companies (whether listed or not), companies that publicly offer or have corporate bonds listed and securities companies.

Decree 47 requires state-owned enterprises to publicly report on the performance of public interest tasks assigned to them (in terms of a plan or bidding), including the following information:^[2]

1. responsibility for environmental protection;
2. responsibility to contribute to the social community;
3. responsibility to suppliers;
4. responsibility to ensure the interests and safety of consumers; and
5. responsibility to ensure benefits of employees in the enterprise.

Decree 08 requires companies that issue green bonds to make annual public disclosures on the assessment results of environmental benefits of projects that use capital raised from the issuance of green bonds.^[3]

Circular 96, Decree 08 and Decree 47 mentioned above are all mandatory.

Circular 96 has a general focus on corporate governance, with specific categories skewed more towards environmental aspects. Decree 47 has a significant focus on social responsibility, whilst Decree 08 focuses on environmental aspects (i.e., the green projects funded by the green bonds).

Although the State Securities Commission of Vietnam (SSC) has welcomed the work of the ISSB and its climate-related reporting requirements, alongside other regulators and standard setters,^[1] IFRS S1 and IFRS S2 have not yet been incorporated into Vietnam’s disclosure requirements.

However, the following international standards are common frameworks that have influenced Vietnam’s sustainability reporting requirements as well as relevant guiding documents to varying degrees:

1. GRI Standards;
2. International Finance Corporation;
3. International Integrated Reporting Council;
4. ISO 26000:2010; and
5. SASB Standards.

In October 2024, the SSC, in collaboration with other organisations, launched the “ESG Handbook”, which provides voluntary guidance and reference materials for Vietnamese enterprises on integrating ESG into corporate governance and enhancing sustainability disclosures. The ESG Handbook recommends international standards, including the TCFD Recommendations, UN Sustainable Development Goals and the EU’s European Sustainability Reporting Standards.^[2]

In addition, the Vietnam Corporate Governance Code 2026, launched by the SSC with support from the IFC on 3 February 2026, refers to several international standards and frameworks, including the IIRC, GRI and ISSB Standards, in its guidance on disclosure and transparency principles and recommends application of these standards in sustainability disclosures by public companies.^[3] However, the Code is intended as a best-practice manual and does not impose mandatory disclosure requirements.

The current regulations of Vietnam (through Circular 96, Decree 08 and Decree 47) can be viewed as adopting an impact materiality approach with certain elements of double materiality.

GHG-emitting establishments are specified in lists issued by the Prime Minister (Specified Establishments) and categorised by sector.^[1] The list of establishments was initially issued in 2022 and most recently expanded in August 2024. These establishments are heavy emitters in specific sectors including energy, transportation, construction, industrial processes, agriculture, forestry and waste.  

The Specified Establishments are subject to biennial GHG inventory reporting, which requires them to report on their GHG inventory method, operation figures and emissions at the facility-level. The requirement to establish GHG inventory reports first applied with a deadline of 31 March 2025 (for reporting period calendar year 2024) and thereafter reporting will be required every two years. There are currently 2,166 Specified Establishments.

Although the list of Specified Establishments is publicly available, this is not the case for the disclosure of GHG emissions. The government is meant to report GHG inventory at a national and sector level through the websites of climate change and sector authorities,^[2] although these announcements have not yet been made.

Circular 96 (described in section A.2 above) imposes public disclosure requirements in respect of GHG emissions, being total direct and indirect GHG emissions and measures and initiatives to reduce GHG emissions

No. However, some companies obtain independent assurance (likely due to contractual undertakings or on a voluntary basis).

No. However, YKVN have advised on a number of recent transactions where issuers of sustainable bonds and borrowers of sustainable financing made voluntary public ESG disclosures.

For example, the voluntary Sustainable Finance Framework of Vietnam Prosperity Joint Stock Commercial Bank (VPBank) was evaluated by Sustainalytics in 2024 and, following this independent assurance, in May 2025 VPBank announced a landmark international syndicated loan transaction with an initial value of US$1 billion.^[1]

A&A Green Phoenix Group Joint Stock Company (Phenikaa) had its Sustainable Finance Framework evaluated by Sustainable Fitch in November 2024 and issued VND 520 billion in dual-tranche sustainability-linked bonds.

Ho Chi Minh City Development Joint Stock Commercial Bank (HD Bank)’s Sustainable Finance Framework has been subject to an independent external review in the form of a Second Party Opinion issued by Moody’s Ratings on 6 December 2024.^[2] In January 2026, HD Bank successfully issued US$100 million green bonds to international investors.^[3]

Yes. On 4 July 2025, the Prime Minister of Vietnam issued Decision No. 21/2025/QD-TTg on environmental criteria and verification of investment projects under the green taxonomy (Decision 21). Decision 21 provides for the environmental criteria and verification procedures applicable to investment projects that satisfy such criteria and are therefore eligible for the State’s preferential policies and support in relation to green credit and green bonds. Credit institutions and foreign bank branches in Vietnam are encouraged to apply this green taxonomy when identifying and providing green credit.

Pursuant to Decision 21, eligible sectors and types of investment projects under the green taxonomy include energy, transportation, construction, water resources, agriculture, forestry, fisheries and biodiversity conservation, processing and manufacturing industry, and environmental services.

Yes. Under Decision No. 941/QD-BTC approving the action plan for the implementation of the Securities Market Development Strategy through 2030, the Ministry of Finance has assigned the SSC to implement a project aimed at enhancing the quality of annual reports of public companies as regards sustainability, based on the application of ESG standards in line with international practices. The project is expected to be implemented through the issuance of legal documents and the organisation of training sessions during 2026-2030. 

On 6 November 2025, the International Conference of the ASEAN Capital Markets Forum (ACMF), to which Vietnam is an active member, launched the ACMF Action Plan 2026-2030 (AP 2026), a forward-looking roadmap for the development of ASEAN capital markets over the next five years.^[1] Among other things, AP 2026 expresses strong support for listed companies in adopting consistent and globally aligned sustainability disclosures, using the ISSB Standards, namely IFRS S1 and IFRS S2, as a building block. The stated objectives of this initiative are to engage with the ISSB, support ASEAN member states in considering or implementing ISSB-adoption roadmaps based on their domestic contexts, and strengthen the sustainability reporting capacity of listed companies in the region.^[2]

It is noted that the ACMF action plan is not a legally binding instrument or treaty, so a member state like Vietnam has no legal obligation to implement such a plan until it voluntarily takes a further step. The SSC, in an attempt to implement AP 2026, launched the Vietnam Corporate Governance Code 2026, which recommends the application of the ISSB Standards in sustainability disclosures by public companies (as mentioned in section A.5 above).

This move suggests that ISSB alignment is a likely direction of travel for Vietnam, although Vietnam has not yet issued a binding domestic roadmap mandating ISSB-based disclosure.

In addition, disclosure requirements imposed on Vietnam’s foreign trade and investment partners (particularly EU entities) would be expected to have an impact on disclosures by their Vietnamese trading partners and exporters, at least to the relevant EU company if not publicly or to any authority. The EU’s CBAM is expected to have a similar effect on exporters of certain goods to the EU.

We therefore expect foreign importers, investors and financiers to impose requirements on Vietnamese companies to disclose certain emissions and other data. This has the potential to impact the local market. 

Yes. At the 26th United Nations Climate Change Conference of the Parties in December 2021, Vietnam set a goal of achieving net zero emissions by 2050. This commitment has since been embedded in a series of policy instruments and, more recently, given operational effect through binding legal measures at the facility level.

Various efforts have been undertaken by the government to achieve this and, notably, in July 2022 the government issued the National Climate Change Strategy to 2050, under Decision No. 896/QD-TTg dated 26 July 2022 of the Prime Minister, which sets out as a general target that Vietnam will reduce GHG emissions under the goal of net zero emissions by 2050. The specific goals include ensuring that:^[1]

1. by 2030, total national GHG emissions will be reduced by 43.5% against business-as-usual;
2. by 2035, emissions peak will be reached; and
3. by 2050, total national GHG emissions will reach net zero emissions.

The National Climate Change Strategy to 2050 sets out the strategies for reducing GHG emissions for each sector. For example, the energy sector promotes clean energy development, economical and efficient energy usage and the agriculture sector applies emission reduction measures through technological innovations in crop cultivation and livestock farming. Subsequently, a series of programmes and action plans for specific sectors were issued to concretise the national strategy, including Decision No. 876/QD-TTg for the transportation sector^[2] and Decision No. 266/QD-TTg for the energy sector.^[3]

The Vietnamese government has also developed Amended Power Development Plan 8 (Amended PDP8) which aims to foster renewable energy projects and reduce GHG emissions. Under Amended PDP8, Vietnam sets a goal, among others, of reducing GHGs caused by electricity production to about 197-199 million tonnes from 2030, and to about 27 million tonnes from 2050. Further, the electricity generation sector must prioritise the construction of projects contributing to reducing GHGs (e.g., biomass, electricity produced from trash, solid waste and cogeneration).

In 2023, the Ministry of Industry and Trade issued Decision No. 947/QD-BCT on approving the Annual Plan for Implementation of Vietnam’s Low Emission Energy Program II, aiming to, among other objectives, reduce GHG emissions in the energy and industrial sectors.^[4]

The most significant recent development is the shift from policy targets to legally binding facility-level obligations pursuant to the establishment of an ETS and carbon market as outlined in section B.2 below. These developments impose increasingly stringent compliance requirements on businesses in respect of their GHG emissions and mitigation activities.

Vietnam is in the process of implementing a full-scale mandatory ETS and voluntary domestic carbon market, with both currently operating in the pilot phase. In the 2025-2026 pilot period, Specified Establishments operating in the thermal power, iron and steel, and cement sectors (Allocated Establishments) are subject to GHG emission quota allocation under a mandatory ETS as outlined below.^[1] The carbon market trades both GHG emissions quotas and carbon credits.

The ETS is expected to operate in two stages: a partially operational phase (2025-2028), and a fully operational phase (beginning in 2029) that would feature emissions quota auctions and international credit trading. In more detail, Decree 06^[2] stipulates the following roadmap and timeline:

1. From now until the end of 2028: establish a national registry system; develop and pilot the operation of the domestic carbon trading exchange (CTX); deploy the domestic carbon credit exchanging and offsetting mechanism; and conduct capacity-building and awareness-raising activities on carbon market development;
2. From 2029 onwards: develop and implement an auction mechanism for GHG emissions quotas; and finalise regulations on carbon credit management, GHG emissions quota trading and carbon credit trading; and regulations on the organisation, management and operation of the domestic carbon market and participation in the international carbon market.

The legal framework for the ETS has been substantially established through the following key instruments: (i) Decree 06 issued by the Government establishing the compliance framework, quota allocation procedures and offsetting mechanisms; (ii) Decree 29^[3] establishing the legal and operational framework for the domestic CTX to be operated by the Hanoi Stock Exchange (HNX); (iii) Circular No. 11/2026/TT-BNNMT^[4] regulating the management and operation of the national registry system for GHG emission quotas and carbon credits; and (iv) Decision 263^[5] approving total GHG emissions quotas for the 2025–2026 pilot period and confirming the list of regulated establishments subject to quota allocation.

GHG emissions quotas will be determined based on statutory methods and allocated to Specified Establishments by the Prime Minister and the Ministry of Agriculture and Environment (MOAE).^[6] During the 2025–2026 pilot period, quota allocation is limited to 110 Allocated Establishments (out of 2,166 Specified Establishments) which are operating in the thermal power, iron and steel, and cement sectors, with total pilot quotas set at 243.1 million tCO₂e for 2025 and 268.4 million tCO₂e for 2026. The remaining Specified Establishments are not yet subject to quota allocation; it is anticipated that further instruments will be issued following the conclusion of the pilot period to extend quota allocation to those establishments, though no binding timeline has been confirmed as of June 2026.

Specifically, one unit of emission quota represents the right to emit one tonne of CO₂ or CO₂-equivalent. Allocated Establishments that exceed their allocated quota may be subject to administrative penalties. In addition, the amount of GHG emissions exceeding the GHG emission quotas allocated will be deducted from the next period’s allocation. Allocated Establishments may use carbon credits from certain projects under the carbon credit exchange and offset mechanisms to offset GHG emissions, and the offsetting must not exceed 30% of the allocated GHG emission quotas. Both GHG emissions quotas and carbon credits will be traded on the CTX established and operated by HNX.

Additionally, a separate carbon credit trading platform will be developed and managed by the International Financial Centre of Vietnam (VIFC) in Ho Chi Minh City and in Da Nang City. Organising domestic and international carbon credit trading markets is included in the list of services prioritised for development by the VIFC.^[7]

On 22 June 2026, the Department of Climate Change under the MOAE signed coordination memoranda with relevant parties in relation to the organisation and operation of the domestic CTX.^[8] These agreements established a unified mechanism for the operations of the carbon trading exchange.^[9] On 29 June 2026, Vietnam's carbon trading exchange officially commenced pilot operations and recorded its first GHG emissions quota transactions, marking a new milestone in the country's energy transition. Initial transaction prices were approximately VND 130,000-136,000 per tCO₂e.^[10]

Alongside the domestic market, Decree No. 112/2026/ND-CP^[11] established a legal framework for the international transfer of GHG emission mitigation outcomes and carbon credits with international partners for the purpose of implementing the Paris Agreement under the UNFCCC. One of the overarching principles is that the transfer of carbon credits abroad must be consistent with Vietnam's international commitments, in particular the mechanism under Article 6 of the Paris Agreement. Rules are in place to regulate the maximum transfer ratio of GHG emission reduction results and carbon credits that are transferred abroad. Businesses must comply with a stringent management process, including preparing and submitting a carbon credit transfer proposal dossier and obtaining prior written regulatory approval for such proposal from the MOAE.

In conclusion, Vietnam's ETS is operational in law, with quota allocations now confirmed.

As of June 2026, Vietnam has neither introduced nor proposed a carbon tax or its own CBAM.

The Law on Environmental Protection^[1] requires Specified Establishments (as mentioned in section A.7 above) to:^[2]  

1. organise the conduct of GHG inventories, develop and maintain a GHG emissions database, and submit GHG inventory results to the MOAE on a biennial basis before 1 December of the reporting period for consolidation and reporting to the Prime Minister;
2. formulate and implement annual GHG emissions reduction plans at the facility level (GHG Reduction Plans) and integrate GHG emissions reduction activities with quality management programmes, cleaner production programmes and environmental protection programmes; and
3. prepare annual reports on GHG emissions reduction levels for the purpose of implementing the facility's GHG Reduction Plan in accordance with the measurement, reporting and verification system, and submit such reports before 31 December of the reporting period.

A GHG Reduction Plan must include specified information including:^[3] (i) GHG inventory results of facilities of the latest year; (ii) estimated GHG emissions in the planning period without application of technology and measures for GHG emissions reduction; (iii) the objective of GHG emissions mitigation of each year in the period from 2026 to 2030; (iv) chosen measures for GHG emissions reduction that are suitable for the actual situation, technological situation, and available resources of the establishments; and (v) a plan for monitoring the implementation of the GHG Reduction Plan.

There are currently no promulgated penalties for a Specified Establishment’s failure to follow the measures or meet the targets set out in its GHG Reduction Plan. However, Allocated Establishments are subject to the GHG emissions quotas mentioned in section B.2 above for the 2025-2026 pilot period. 

For public (and certain other) companies, the annual report required under Circular 96 (see section A.2 above) contains certain disclosure requirements on initiatives to reduce GHG emissions.^[4]

Furthermore, in relation to ozone-depleting substances and/or controlled greenhouse effect substances (as identified by the government):

1. enterprises that manufacture products containing or using such substances are obliged to develop an appropriate roadmap to replace and eliminate such substances (in accordance with treaties to which Vietnam is a party); and^[5]
2. enterprises using equipment or products containing or using such substances shall comply with regulations on the collection, transportation, recycling, reuse and disposal of such substances (in accordance with the MOAE’s guidelines).^[6]

In the banking sector, the State Bank of Vietnam (SBV) issued Circular No. 17/2022/TT-NHNN on internal credit rating systems, which requires credit institutions (i.e. banks) to integrate environmental and social factors into their risk management processes and credit decisions.^[7]

Yes, see section B.3 above for mandatory requirements for Specified Establishments to formulate and implement a GHG Reduction Plan in accordance with their respective allocated GHG emissions quotas, which will require such establishments to set GHG reduction targets.

The MOAE is responsible for notifying and updating information on the list of GHG emissions quotas allocated to individual establishments. However, facility-level quota allocations have not yet been published. To date, only the total pilot GHG emissions quotas at the sector level for 2025 and 2026 have been approved under Decision 263 as noted in section B.2 above.

Local environmental protection law imposes mandatory circular economy requirements. As a general principle, production, business, and service establishments are responsible for establishing management systems and implementing measures to reduce resource extraction, minimise waste, and increase the reuse and recycling of waste from the project construction and product design stages through to production and distribution.^[1]

Circular-economy criteria

General criteria for the circular economy include the following:^[2]

1. reduce the extraction and use of non-renewable resources and water resources; improve the efficiency of using resources, raw materials, and materials; and conserve energy;
2. extend the useful life of materials, equipment, products, goods, and their components and parts; and
3. limit waste generation and reduce adverse environmental impacts, including by reducing solid waste, wastewater, and emissions; reducing the use of hazardous chemicals; recycling waste; recovering energy; reducing single-use products; and promoting green procurement.

Measures to achieve the circular-economy criteria

The National Action Plan for Implementing the Circular Economy to 2035, issued by the Prime Minister under Decision No. 222, ^[3] sets a target of reducing GHG emissions intensity per unit of GDP by at least 15% by 2030 compared to 2014.^[4] The priority sectors and fields for implementing the circular economy through to 2035 include: (i) agriculture, forestry and fisheries; (ii) energy; (iii) mineral extraction and processing; (iv) manufacturing and processing industries; (v) chemicals; (vi) construction; (vii) transport; (viii) services and tourism; (ix) waste management; and (x) development of urban areas and concentrated residential zones; industrial parks, industrial clusters, and concentrated production, business and service zones.^[5]

Decree 08 provides that based on the National Action Plan for Implementing the Circular Economy, enterprises in certain sectors must implement the following measures in order of priority to meet the circular economy criteria:

1. for production, business, and service establishment projects: (i) limit non-environmentally friendly products; (ii) optimise the use of equipment, products, resources, materials, and inputs; (iii) extend product and component life cycles; and (iv) reduce waste generation;^[6]
2. for concentrated production, business, and service area and industrial cluster projects: (i) optimise overall site planning and interconnection among projects to improve efficiency and reduce land, water, mineral, and energy consumption; increase recycling and cut total waste; (ii) develop and use clean and renewable energy; (iii) collect, store, and reuse rainwater; collect, treat, and reuse wastewater; and (iv) carry out industrial symbiosis in accordance with law; and^[7]
3. for urban development and concentrated residential area projects: (i) optimise overall site planning to improve efficiency and reduce land, water, and energy consumption; (ii) apply environmentally friendly transport solutions to reduce GHG emissions; (iii) develop and use clean and renewable energy in line with law; and (iv) implement other environmental protection measures required by law. ^[8]

EPR schemes

Local environmental protection laws include EPR-related provisions. Enterprises producing and/or importing products and packaging with recyclable value are required to recycle such products and packaging in accordance with mandatory recycling rates and specifications (as prescribed under Decree No. 110/2026/ND-CP^[9]).^[10] Such enterprises must choose to fulfil their recycling obligations in one of the following forms: (i) organising the recycling of products and packaging themselves; or (ii) making financial contributions to the Vietnam Environment Protection Fund to support the recycling of products and packaging.^[11] In addition, enterprises (other than those choosing to make financial contributions to the Vietnam Environment Protection Fund) must register a recycling plan and submit recycling results reports in the statutory form to the MOAE before 1 April of each year.^[12]

Enterprises producing and/or importing products and packaging containing hazardous substances, that are difficult to recycle or that create difficulties for collection and treatment, are required to make financial contributions to support waste treatment activities.^[13] Such enterprises shall make financial contributions to the Vietnam Environment Protection Fund with the level of financial contribution determined by the weight or unit of products or packaging, and declare and pay the full contribution amount as specifically prescribed under Decree 110.^[14]

Violations of regulations on producers' and importers' product recycling obligations or waste treatment obligations shall, depending on the nature and severity of the violation, be subject to administrative fines ranging from VND 100 million to VND 2 billion, together with remedial measures as prescribed.^[15]

Energy efficiency standards and labelling

Vietnam applies a system of mandatory minimum energy performance standards (MEPS) and energy labelling requirements, as provided under the Law on Economical and Efficient Use of Energy^[16] and implemented in detail under Decree No. 30/2026/ND-CP.^[17]

Under Circular No. 52/2025/TT-BCT^[18] of the Ministry of Industry and Trade, from January 2026, the first group of 15 product categories subject to mandatory energy efficiency labelling includes household appliances (air conditioners and refrigerators), office equipment (laptops and commercial refrigerators) and industrial equipment (distribution transformers). Certain products such as induction cookers and desktop computers are subject to voluntary labelling from 2026, transitioning to mandatory labelling from 1 January 2027. 

Vietnam does not have any mandatory environmental and/or human rights due diligence obligations for businesses that operate in a similar manner to the EU’s CSDDD.

Notwithstanding the above, Vietnam has disclosure obligations requiring companies to disclose their environmental information and to prepare, publish and update various environmental reports. In addition, Vietnam published a National Action Plan for Law and Policy Improvement to Promote Responsible Business Practices in Vietnam in July 2023, which outlines high-level actions to improve policies and laws on labour, the protection of the rights of vulnerable groups, environmental protection and consumer protection.

Green taxonomy

The Law on Environmental Protection and Decree 08 have established the legal foundation for green credit and green bonds, under which an investment project must satisfy certain environmental criteria to be eligible for green credit or the issuance of green bonds. Specifically, green credit is extended to investment projects that: (a) use natural resources efficiently; (b) respond to climate change; (c) manage waste; (d) treat pollution and improve environmental quality; (e) restore natural ecosystems; (f) conserve nature and biodiversity; and (g) generate other environmental benefits.^[1] Green bonds are bonds issued by the Government, local authorities, or enterprises to raise capital for environmental protection activities and investment projects that bring environmental benefits.^[2]

On 4 July 2025, Vietnam issued Decision 21, which established the official framework for certifying investment projects as green projects under the green taxonomy. Decision 21 identifies 45 types of projects across 7 major sectors, including energy; agriculture, forestry, fisheries and biodiversity; transport; manufacturing and processing; construction; environmental services; and water resources. To be certified as falling within the green taxonomy, an investment project must: (a) obtain a decision approving the results of the appraisal of the environmental impact assessment report, or an environmental permit, or environmental registration in accordance with environmental law, except for projects exempt from environmental procedures under the law; and (b) fall within an environmental protection sector or generate environmental benefits and satisfy the requirements set out in Appendix I to Decision 21.^[3]

As for green credit, the SBV directs and guides credit institutions to prioritise and arrange appropriate funding sources to provide preferential loans that encourage investors to implement projects included in the green taxonomy list; and supports credit institutions in receiving foreign grants and concessional loans to finance projects included in the green taxonomy list.^[4]

Financial incentives and subsidies

Issuers of green bonds and green bond investors are entitled to the following incentives: (a) service fee incentives (for example, a 50% reduction in the registration and listing service fees for issuers and investors)^[5]; and (b) public investment projects funded from green bond proceeds are given priority in the allocation of sufficient capital in line with the project implementation schedule under the medium-term and annual public investment plans.^[6]

Income from green bond interest and income from the initial transfer of green bonds after issuance are exempt from corporate income tax.^[7]

Resolution No. 198/2025/QH15^[8] provides that enterprises in the private sector, household businesses, and individual business households are entitled to a 2% annual interest rate subsidy from the State when borrowing to implement green projects, circular economy projects, and projects applying ESG standards. The SBV is currently submitting to the Government a draft decree on this interest subsidy policy.^[9]

Blended finance

Blended finance initiatives include Vietnam’s participation in the Just Energy Transition Partnership (signed in December 2022) and its Resource Mobilisation Plan, which comprises US$15.5 billion committed by the International Partners Group, setting out priority investments, policy measures, and legal reforms to accelerate the transition to renewable energy.^[10]

Vietnam’s approach is to encourage investment in greenfield and brownfield projects involving transformative technologies that lower GHG emissions, as well as encourage participation in mechanisms and modes of cooperation that lower GHG emissions.

The Government has launched the Sustainable Business Support Programme for the period 2026-2030,^[1] with the goal of supporting approximately 25,000 business entities on their sustainable development initiatives through advisory support, science and technology assistance, digital transformation, and communications and trade promotion activities.  The three sustainable business models supported under the programme are (a) the circular economy business model, (b) the inclusive business model, and (c) the ESG business model and other sustainable business models.

The SSC will conduct a review with a view to amending and supplementing Circular 96 on information disclosure in the securities market, including a review and revision of provisions on sustainability reporting for listed companies and public companies, so that disclosed information will more closely reflect international practice as mentioned in section A.12 above.

Apart from the State, market participants have been placing increased focus on ESG with media attention on those companies making positive strides. There is a growing corporate culture of setting ESG goals.

External influence by way of Vietnam’s trading and investment partners will increasingly affect the local market, driven by requirements of their home jurisdictions as well as voluntary positions adopted. Foreign investors are placing greater emphasis on investee companies transitioning. 

No. There have, in the past, been incidents of greenwashing which sparked public anger. However, there have not been any recent legal proceedings or regulatory enforcement actions.

Vietnam has not adopted laws or regulations specifically dealing with greenwashing. The Law on Competition,^[1] Law on Advertising,^[2] Law on Protection of Consumer’s Rights,^[3] Law on Securities^[4] and the Penal Code^[5] regulate false information about products or the enterprise itself. The Civil Code^[6] allows for claims by those suffering harm. In addition, environmental claims are indirectly disciplined through the Vietnam Eco-label regime, under which the MOAE sets the criteria for, and certifies, environmentally friendly products and services.^[7] Significantly for greenwashing, an eco-label certification may be revoked where the product or service no longer meets the applicable criteria, or where the holder fails to maintain the commitments given in its certification dossier - providing a State-backed basis for substantiating green claims and a mechanism to withdraw them where they cease to be accurate.

Environmental marketing that is inconsistent with, or that falsely asserts, a Vietnam Eco-label certification could provide a further basis for action: such claims may be challenged as misleading under the consumer-protection, advertising and competition laws referred to above, and the relevant producer or service provider may separately have its Vietnam Eco-label certification revoked by the MOAE.

There is an intersection with corporate governance in the sense that directors could be liable for failure to adhere to their duties.

Where there is harm suffered, compensation for damages could also be another ground.