As part of Vietnam’s roadmap toward achieving its Net Zero commitment by 2050, greenhouse gas (GHG) emissions management has become a mandatory and increasingly important legal requirement. For businesses, understanding whether they are subject to mandatory GHG inventory and corporate carbon reporting obligations is essential not only for legal compliance but also as a critical step toward participating in the emerging carbon credit market. With the latest legal developments effective through 2026, these requirements have become more detailed and stringent than ever before.
In this article, Law Plus provides an updated overview of the key regulations that enterprises should be aware of in order to comply with the requirements of Decree No. 06/2022/ND-CP.
Table of Contents/Mục lục
1. Current legal framework on greenhouse gas inventories
The legal framework governing greenhouse gas emission reduction activities in Vietnam is primarily based on the Law on Environmental Protection 2020. To provide detailed guidance, the Government issued Decree No. 06/2022/ND-CP, which regulates greenhouse gas emission mitigation and ozone layer protection.
However, businesses should note that, from 01 August 2025, Decree No. 119/2025/ND-CP officially took effect, amending and supplementing several important provisions of Decree No. 06/2022/ND-CP to further develop the National Registry System for Emission Allowances and Carbon Credits. Compliance with both Decree No. 06/2022/ND-CP and the updated provisions under Decree No. 119/2025/ND-CP is mandatory for organizations and individuals engaged in emission-generating activities within Vietnam.
2. Determining which enterprises are required to conduct greenhouse gas inventories
Pursuant to Article 5 of Decree No. 06/2022/ND-CP, entities subject to mandatory greenhouse gas inventories are identified based on specific quantitative thresholds. Businesses should compare their operational data against the criteria stipulated in Clause 1, Article 6 of the Decree, as follows:
– Facilities in key sectors: Facilities operating in the fields of energy, agriculture, land use and forestry, waste management, and industrial processes are required to conduct greenhouse gas inventories if their annual emissions reach 3,000 tons of CO₂ equivalent (CO₂e) or more.
– Major energy consumers: This category includes Industrial production facilities; Agricultural production facilities; Transportation enterprises; with annual energy consumption of 1,000 tons of oil equivalent (TOE) or more; and Commercial buildings with annual energy consumption of 1,000 TOE or more.
– Solid waste treatment facilities: Facilities with an annual design capacity of 65,000 tons or more are also subject to mandatory greenhouse gas inventories.
The specific list of applicable facilities is issued and updated by the Prime Minister every two years. Enterprises should proactively verify whether they are included in the latest list. If subject to mandatory inventory requirements, businesses must submit periodic inventory reports to the Ministry of Agriculture and Environment before 01 December of the reporting period for consolidation purposes.
3. Key sectors required to prepare corporate carbon reports
In addition to emission thresholds, the law also determines reporting obligations based on industry sectors. Pursuant to Clause 3, Article 1 of Decree No. 119/2025/ND-CP (amending Article 7 of Decree No. 06/2022/ND-CP), greenhouse gas mitigation efforts focus on several priority sectors. Enterprises that meet the applicable thresholds and operate in the following sectors are required to implement emission reduction measures and prepare specialized carbon reports:
Energy Sector: Energy production; Energy consumption in industry; Construction; Transportation; Commercial and residential sectors.
Transportation Sector: Road transportation; Railway transportation; Inland waterway transportation; Aviation transportation.
Construction Sector: Building material manufacturing; Large-scale construction projects with significant emissions.
Industrial Processes Sector: Chemical manufacturing; Metallurgical production; Production of non-metallic mineral products.
Agriculture, Forestry and Land Use Sector: Livestock production; Crop cultivation; Land-use change activities.
Waste Management Sector: Solid waste treatment; Wastewater treatment.
4. Reporting Timeline and Procedures for 2026–2027
One of the most significant updates that enterprises should pay attention to in 2026 concerns the reporting roadmap. Under Clause 6, Article 1 of Decree No. 119/2025/ND-CP, which amends Article 10 of Decree No. 06/2022/ND-CP, the reporting process is as follows:
Preparation During 2026: Facilities subject to mandatory reporting requirements must complete the measurement, collection, and management of emission data and establish online emissions databases throughout 2026.
Submission Deadline: Enterprises must prepare an annual greenhouse gas mitigation report for the preceding reporting year (using Form No. 02) and submit it to the relevant provincial-level People’s Committee no later than 31 March 2027.
Accordingly, businesses must complete emission monitoring and data collection throughout 2026 to prepare for the first formal reporting cycle in early 2027. The submitted reports will be verified by authorized entities designated by the Ministry of Agriculture and Environment. Verification results will serve as a basis for the allocation of greenhouse gas emission allowances in subsequent periods.
5. National Registry System and Corporate Responsibilities
Through Decree No. 119/2025/ND-CP, the Government established the National Registry System for Greenhouse Gas Emission Allowances and Carbon Credits.
According to Point e, Clause 2, Article 1 of Decree No. 119/2025/ND-CP, this technical infrastructure system is designed to manage ownership information and facilitate borrowing, surrendering, and transferring emission allowances. Enterprises subject to mandatory compliance are responsible for:
– Providing operational information and activity data required for monitoring, reporting, and verification activities as requested by competent authorities (pursuant to Clause 5, Article 1 of Decree No. 119/2025/ND-CP, amending Clause 6, Article 9 of Decree No. 06/2022/ND-CP);
– Strictly complying with the Monitoring, Reporting, and Verification (MRV) framework (pursuant to Clause 3, Article 1 of Decree No. 119/2025/ND-CP, amending Point b, Clause 4, Article 7 of Decree No. 06/2022/ND-CP);
– Surrendering the quantity of emission allowances or carbon credits corresponding to the greenhouse gas emissions generated during the reporting period.
6. Conclusion
Conducting greenhouse gas inventories and preparing corporate carbon reports under Decree No. 06/2022/ND-CP, as amended by Decree No. 119/2025/ND-CP, is no longer a voluntary activity but a legal obligation directly linked to the economic interests of enterprises.
Businesses with annual emissions of 3,000 tons CO₂e or more or annual energy consumption of 1,000 TOE or more should promptly strengthen their environmental management systems and establish reliable emissions data management processes to meet upcoming reporting requirements. Compliance with environmental regulations is not only a legal necessity but also one of the most effective ways for enterprises to enhance competitiveness and achieve sustainable growth in the era of the green economy.
