You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

February 11, 2025

Vietnam to Establish and Develop Carbon Market

Subscribe to Updates

On January 24, 2025, the prime minister of Vietnam issued Decision No. 232/QD-TTg, approving the proposal for establishment and development of a carbon market in Vietnam. The decision establishes a compliance mechanism for greenhouse gas (GHG) emitters and creates opportunities for investors interested in carbon trading in Vietnam.

Market Development Roadmap

Decision 232 establishes a phased approach to developing Vietnam’s carbon market, with the following ambitious milestones:

  • Before June 2025 (preparation period): The legal framework for trading of emissions quotas and carbon credits and a carbon-credit offset exchange mechanism will be developed, along with the necessary infrastructure for organization and operation of the carbon-credit market.
  • From June 2025 to the end of December 2028 (pilot period): A pilot domestic carbon exchange will be launched, with continued legal refinements.
  • From 2029 (official launch period): The carbon market will be fully operational.

Carbon Market Structure and Trading Mechanisms

Vietnam’s carbon market will function as a centralized, government-regulated exchange, trading two main assets:

  • GHG emissions quotas (allowances) allocated to regulated emitters, which can be traded or auctioned; and
  • Carbon credits generated from domestic and international projects that are certified for trading. The carbon credits generated from international projects include those originating from international exchange or offset-crediting mechanisms such as the Clean Development Mechanism (CDM), the Joint Credit Mechanism (JCM), and Article 6 of the Paris Agreement.

The National Registration System for GHG emissions quotas and carbon credits will be primarily developed and operated by the Ministry of Natural Resources and Environment.

Transactions of GHG emissions quotas and carbon credits will occur on the domestic carbon exchange, managed by the Hanoi Stock Exchange, and will follow a centralized process where verified quotas and credits receive unique domestic codes for trading and participants must have depository accounts. The Vietnam Securities Depository and Clearing Corporation will handle registration, depository, and payment services. Automated systems will process payments based on trade results, ensuring simultaneous asset transfer and payment settlement via qualified commercial banks.

Pilot Participants and Recommendations for GHG Emitters and Investors

For the pilot period, large GHG emitters, which will be allocated free emissions quotas, and organizations or individuals eligible for trading carbon credits can participate in the pilot carbon exchange. After that, the government will consider expanding participation in carbon-credit trading by adjusting eligibility conditions for organizations and individuals on the carbon exchange.

GHG emitters and investors should stay informed about Vietnam’s evolving carbon market regulations to be well prepared for participation in the carbon market. Emitters should conduct GHG inventories, submit reports biennially, implement annual emission mitigation plans, and manage allocated emission allowances within the domestic carbon market. Investors should assess regulatory developments and seek expert advice to navigate compliance obligations and identify market opportunities.

Related Professionals

Industries

Energy

Practices

Capital Markets

Corporate/M&A

Location

RELATED INSIGHTS​ 

June 25, 2025
In April 2025, a massive power outage plunged Portugal, Spain, and parts of southwestern France into darkness for up to ten hours. As Thailand advances its energy transition by increasing renewable integration and regional interconnections, the European blackout serves as a stark reminder of the grid vulnerabilities that still exist. In this first article of a three-part series, energy specialists from Tilleke & Gibbins examine the root causes of the outage in the Iberian Peninsula.
Read More
May 28, 2025
Tilleke & Gibbins attorneys in Vietnam have contributed the 2025 edition of Doing Business in Vietnam, a comprehensive Q&A-style resource from Thomson Reuters Practical Law that provides essential insights for companies navigating business operations in Vietnam. The guide presents a detailed overview of the country’s legal framework and regulatory environment, reflecting recent updates in Vietnamese legislation and practice. This annually updated guide offers key information on the following areas: Legal system: Structure of the Vietnamese judiciary and the role of codified law. Foreign investment: Conditions for market access, licensing requirements, foreign ownership restrictions, and investment incentives. Business vehicles: Formation and operation of legal entities, including limited liability companies, joint-stock companies, and representative offices. Employment: Employment contracts, social insurance, labor rights, and procedures for hiring foreign nationals. Tax: Overview of corporate income tax, personal income tax, value-added tax, and other tax obligations. Intellectual property: Procedures for protecting and enforcing patents, trademarks, copyrights, and other IP rights. Data protection: Compliance requirements under Vietnam’s data privacy laws, including the Personal Data Protection Decree. Competition law: Antitrust rules and regulatory oversight under the Law on Competition. Anti-bribery and corruption: Legal framework and enforcement practices aimed at curbing corrupt activities. E-commerce and digital business: Regulations governing online platforms, digital content, and cross-border services. Marketing and advertising: Laws and guidelines on advertising standards and consumer protection. Product regulation and liability: Safety requirements, product liability issues, and roles of relevant authorities. Doing Business in Vietnam is part of Practical Law’s global series of legal guides designed to support international practitioners and businesses. To access the most recent edition of the Vietnam guide, visit the Practical Law website and sign up for a free trial.
Read More
May 2, 2025
Attorneys from Tilleke & Gibbins have updated the latest edition of Doing Business in Thailand, a Q&A-style guide from Thomson Reuters Practical Law that offers an overview of key legal considerations for companies operating in jurisdictions worldwide. The contribution outlines the country’s legal and regulatory framework for foreign investment and business operations and reflects the latest legislative developments. The chapter addresses the following core topics: Legal system: Structure of the courts and the codified nature of Thai law. Foreign investment: Business restrictions under the Foreign Business Act, sector-specific regulations, exchange control rules, and investment incentives. Business vehicles: Overview of partnerships, private and public limited companies, and other legal entities. Employment: Labor protections, employment contracts, foreign worker requirements, and termination procedures. Tax: Corporate and personal income tax, indirect taxes, and tax obligations for residents and non-residents. Intellectual property: Registration and enforcement of patents, trademarks, designs, and copyrights. Data protection: Key provisions of the Personal Data Protection Act and related compliance obligations. Competition law: Regulatory framework under the Trade Competition Act. Anti-bribery and corruption: Relevant legislation and enforcement mechanisms. E-commerce and digital business: Legal regime for online transactions and digital platforms. Marketing and advertising: Consumer protection laws and regulations affecting advertising and marketing practices. Product regulation and liability: Safety standards, liability regimes, and roles of enforcement authorities. Practical Law, a legal reference resource from Thomson Reuters, publishes a range of guides for hundreds of jurisdictions and practice areas. The insurance and reinsurance guide is a valuable resource for legal practitioners, covering numerous jurisdictions worldwide. To view the latest version of the guide, please visit the Practical Law website and enroll in the free Practical Law trial to gain full access.
Read More
April 10, 2025
On March 3, 2025, the government of Vietnam issued Decree No. 57/2025/ND-CP, regulating the direct power purchase agreement (DPPA) mechanism between renewable energy generators and large electricity consumers (“Decree 57”). Decree 57 took immediate effect and replaces Decree No. 80/2024/ND-CP on the same subject. The new regulations enable investors to kickstart their investment plans for DPPAs in Vietnam. Below are the key changes and provisions of Decree 57. Participants in On-Grid DPPAs Decree 57 expands the eligibility criteria for participating in DPPAs via the national grid (on-grid DPPAs): Sellers: In addition to wind and solar power generators, biomass energy generators with a capacity of 10 MW or more can now participate. Buyers: Electric vehicle charging businesses are now eligible to participate, broadening the scope beyond just production businesses. Large Electricity Consumers Instead of setting definite criteria at the government decree level, Decree 57 defines large electricity consumers based on average electricity consumption as set out in wholesale electricity market regulations to be issued by the Ministry of Industry and Trade (MOIT). Although the threshold for DPPA participation remains for now at 200,000 kWh per month, Decree 57 will allow the MOIT to adjust this threshold as deemed necessary. Decree 57 also provides specific guidance for large electricity consumers based on their consumption period. To participate in both private off-grid DPPA (selling electricity directly via a grid system separate from the national grid) and on-grid DPPA models, large electricity consumers must meet the minimum threshold for electricity consumption set by the MOIT under the Vietnam wholesale electricity market regulations (“Minimum Consumption Threshold”). Consumers with a consumption history of at least 12 months must have already met the Minimum Consumption Threshold at the time of registration or notification, while those whose consumption period is less than 12 months must commit to
Read More