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  1. Environment & Climate Change
  2. Vietnam: Comprehensive regulatory framework for the carbon market underway

Vietnam: Comprehensive regulatory framework for the carbon market underway

28 Oct 2025    4 minute read
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Carbon Market Net-zero Emissions GHG Reduction Emissions Trading Scheme (ETS) International Carbon Credits Energy Transition Sustainability

In brief

Vietnam is actively developing a centrally managed domestic carbon market, with a pilot phase from late 2026 to 2028 and full implementation scheduled for 2029. This development has been identified as a pivotal strategy to achieve its greenhouse gas (GHG) emission reduction targets by 2030 and ultimately reach an ambitious goal of reaching net-zero emissions by 2050, which aligns with Vietnam’s broader environmental and economic objectives.


Contents

To support this roadmap, the government has issued various regulations to facilitate the implementation of Vietnam’s carbon credits trading market. In particular:

  • In January 2025, the Prime Minister approved Decision No. 232/QĐ-TTg, which outlines a roadmap for establishing a domestic carbon market, and builds on the Law on Environmental Protection 2020 (“LEP 2020”) and Decree No. 06/2022/ND-CP (“Decree 06”).
  • LEP 2020 includes provisions for establishing and developing a carbon market, marking a significant milestone for Vietnam, while Decree 06 sets the groundwork for carbon market operations. Decree 06 was revised by Decree No. 119/2025/ND-CP on 9 June 2025.
  • To ensure the credibility of carbon credits and global climate commitments, Vietnam is aligning its carbon market regulations with international standards, especially the nationally determined contributions (NDC) under the Paris Agreement.

Key takeaways

  • Vietnam’s legal framework for the carbon market targets major GHG-emitting sectors, in accordance with the country’s conditions, provisions of law, and international commitments and treaties.
  • The domestic legal structure is designed to align with the NDC, ensuring transparency and avoiding double counting, which is crucial for unlocking the economic potential of carbon credits and shaping the pricing of future internationally transferred mitigation outcomes (ITMOs).
  • In the pilot phase, the Ministry of Natural Resources and Environment (MONRE), now the Ministry of Agriculture and Environment (MAE), will preside over the development of the domestic carbon market; manage measurement, reporting and verification (MRV) systems; and coordinate with other ministries to set quotas and trading rules.

In more detail

Vietnamese legal landscape for GHG emission reduction and carbon market

Pursuant to Article 5 of Decree 06, and under the Emissions Trading Scheme (ETS), the largest GHG emitters will be required to take emissions inventories and allowance allocations, including the following:

  • Energy and power generation.
  • Manufacturing and heavy industry.
  • Transportation.
  • Agriculture and waste management.
  • Construction and real estate.

Under Article 91 of LEP 2020, the GHG emission reduction process is implemented through the roadmap and methods in accordance with the country’s conditions, provisions of law and international commitments and treaties.

To ensure the credibility of carbon credits and uphold its global climate commitments, Vietnam is aligning its regulations with international standards: “International carbon credit transactions must prioritize national emission reduction goals.”

This comes with an emphasis that all projects must adhere to the country’s NDC under the Paris Agreement, which requires adjusting Vietnam’s emission reports to accurately reflect the emission reduction results transferred to international partners, prevent double counting, and enhance transparency.

In addition, the roadmap involves managing, measuring, inspecting, reporting and appraising GHG emission reduction in many aspects, at the national, sectoral and relevant facility levels.

Under Decree 06, the MONRE/MAE will (i) take the lead and coordinate with the Provincial People’s Committees and ministries specified in Article 5.2 of Decree 06, to review, consolidate and develop a list of sectors and facilities required to conduct GHG inventories and submit it to the prime minister for promulgation; and (ii) submit for the prime minister’s approval the updated list of sectors and facilities required to conduct GHG inventories every two years.

In addition, the MONRE/MAE will issue enabling regulations, oversee governance, and manage the national registry and MRV systems. Under Article 139 of LEP 2020, the MONRE/MAE is responsible for:

  • Submitting the total GHG emission quota, by phase and annually, to the prime minister for approval.
  • Organizing the allocation of GHG emission quotas to the subjects listed in Article 139.2 of LEP 2020.
  • Organizing the operation of the domestic carbon market and participating in the world carbon market.

Meanwhile, the Ministry of Finance will preside over and coordinate with the MONRE/MAE and relevant ministries and ministerial-level agencies the establishment of a domestic carbon market.

Toward international carbon credits trading

Vietnam’s carbon market is in the process of formation and development, aiming for net-zero emissions by 2050. Preparations are underway for a pilot carbon trading platform starting late 2026, one year behind the original plan, and official operation in 2028, in parallel with the sale of forest carbon credits to the international market.

Immediately following the 26th United Nations Climate Change Conference (COP26), the Vietnamese government — through the Department of Climate Change (under MAE) — outlined a plan to implement the net-zero commitment with five key solution groups: (i) energy conversion, (ii) energy saving, (iii) protection and development of forest ecosystems, (iv) carbon capture and storage, and (v) carbon pricing. Moreover, Vietnam aims to create a trading environment that balances economic opportunities with sustainable environmental practices.

The Vietnamese government is establishing the necessary regulatory framework for developing the domestic carbon market and managing its operations to remove barriers for businesses. The regulator is also responsible for incorporating both an ETS and a market for carbon credits.

What’s next?

Several legal and regulatory gaps could affect business readiness, including sector-specific guidelines, carbon credit recognition and trading rules, etc. The MONRE/MAE is actively working on the following aspects to provide more clarity in the market in the upcoming pilot phase:

  • Finalizing GHG emission limits and allocation plans for covered entities.
  • Issuing enabling regulations for carbon credit recognition, trading infrastructure and compliance enforcement.
  • Building capacity and infrastructure for MRV and registry systems.
Contact Information
Yee Chung Seck
Partner
Ho Chi Minh City
Read my Bio
yeechung.seck@bakermckenzie.com
Lan Phuong Nguyen
Partner
Ho Chi Minh City
Read my Bio
lanphuong.nguyen@bakermckenzie.com
Phuc Thuy Hien Nguyen
Senior Associate
Ho Chi Minh City
Read my Bio
thuyhien.nguyen@bakermckenzie.com

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