Vietnam’s Carbon Market Takes Shape. What Businesses Need to Know

Dec 2

Vietnam officially launched the pilot phase of its emissions trading scheme (ETS) in June 2025, targeting three carbon-intensive sectors: power generation (thermal coal), steel, and cement. This pilot ETS covers roughly 50% of Vietnam’s CO₂ emissions during 2025–2028, a significant share reflecting these sectors’ outsized carbon footprint (by some estimates, they account for ~70% of national emissions). Under the scheme, large emitters in these industries are allocated emissions allowances free of charge based on intensity benchmarks (CO₂ per unit of output). Because the cap is intensity-based rather than an absolute tonnage cap, total emissions are not strictly fixed at a set level – the effectiveness will hinge on how strictly those benchmarks are set and tightened over time. Companies must monitor and report their greenhouse gas output, and by the end of 2025 they are slated to receive their first batch of allowances covering 2025–2026 emissions. If a firm’s emissions exceed its free allowance, it will need to buy carbon credits to cover the shortfall on the new carbon market. Importantly, the rules also let companies offset up to 30% of their emissions using eligible carbon credits from low-carbon projects (domestic or international). This offset provision was designed to give flexibility, though it was expanded from an initially proposed 10% limit after industry consultations.

Context: The pilot ETS is a central pillar of Vietnam’s climate strategy, aiming to reach net-zero emissions by 2050. It comes at a time when Vietnam’s CO₂ output is rising steeply – coal-fired power generation jumped nearly 18% in 2024, and crude steel production rose 15%. Recognizing that immediate deep cuts are unlikely during the pilot, officials have emphasized that the initial priority is to help industries adapt to carbon pricing rules rather than force abrupt emission reductions. As analyst Mai Duong noted, the generous free allowances in the first phase mean the ETS’s short-term impact on emissions will be limited; the focus is on building capacity and systems for the longer term. Nevertheless, Vietnam’s move is considered a pivotal step to incorporate market-based incentives into its climate policy and eventually bend its emission trajectory downward.

Coverage and Allowance Allocation in the Pilot Phase

Approximately 150 major emitting enterprises are included in the pilot carbon market. These were selected as the largest CO₂ emitters in the power, steel, and cement industries, ensuring that the bulk of each sector’s emissions are regulated. For example, Vietnam’s ETS will cover only 27 out of 300+ steel production facilities, but those 27 sites account for over 80% of the steel sector’s emissions. Similarly, only 56 clinker (cement) plants – about 90% of cement industry emissions – are in the pilot. By targeting the heaviest emitters, the scheme captures most emissions with relatively few participants. All covered facilities receive an emissions quota (allowance) for free during the pilot years, calculated based on sector-specific carbon intensity benchmarks and production data. These benchmarks function similarly to China’s approach – allocating permits per unit of output – and will be tightened over time to increase pressure to reduce emissions.

The first allocation of allowances (for 2025–2026) is scheduled by December 31, 2025. Line ministries (e.g. Industry and Trade for power/steel, Construction for cement) have submitted proposed allocations for each installation, which the Ministry of Agriculture and Environment (MAE) will consolidate and issue upon the Prime Minister’s approval. Subsequent allocations for 2027–2028 and 2029–2030 will follow a similar cycle, with proposals due mid-year and final quotas approved by late October of the preceding year. During the pilot period (2025–2028), all these allowances are granted free of charge – there is no auctioning yet. This approach cushions industries in the early years but also means the carbon price signal may be modest until free allocations wind down. Indeed, Vietnam plans to introduce permit auctions from 2029 onward once the market matures.

Industry readiness: A key challenge has been getting companies ready for the ETS. By 2025, many firms were still developing the capacity to track and manage their emissions. A recent survey revealed that only about one-third of Vietnam’s large companies had even conducted a GHG emissions inventory, and fewer than 11% had their emissions data externally verified. This underscores the work needed to implement robust measurement, reporting, and verification (MRV) across industry. To address this, authorities (with support from international partners) have been running training programs and simulation exercises for the affected sectors. These trainings cover how to do emissions inventories, how allowances and offsets work, and even mock carbon trading on the Hanoi Stock Exchange platform. The goal is to ensure that by the time companies receive their quotas and face compliance obligations, they understand the rules and can participate effectively in the carbon market.

Regulatory Developments and Timeline Adjustments

After the June launch, Vietnam has been busy fine-tuning the ETS regulatory framework and infrastructure. On June 9, 2025, the government issued Decree 119/2025/ND-CP, a revision of earlier carbon market regulations, which lays out detailed rules for the pilot ETS. This decree confirmed the pilot phase would run through the end of 2028, with the full ETS becoming operational in 2029. It also formally merged oversight of climate policy into the new Ministry of Agriculture and Environment (MAE), after combining the former environment ministry (MONRE) with the agriculture ministry. Under Decree 119, MAE is responsible for running the ETS pilot – setting up the allowance allocation, MRV systems, and compliance procedures – in coordination with other ministries. The Hanoi Stock Exchange (HNX) has been assigned to develop and operate the carbon trading platform, while the Ministry of Finance handles the financial market aspects.

Initial delays: Although the pilot formally “launched” in 2025, the actual trading of carbon units has not begun as quickly as initially hoped. Trading was originally expected to commence by mid-2025, shortly after the scheme’s launch, but this was postponed. In late July 2025, MAE announced that the first carbon market transactions would likely occur toward the end of 2025 instead. The reason for the delay is that several enabling pieces were still missing: Vietnam lacked finalized trading regulations and a national carbon credit registry. In fact, a separate decree to govern the carbon trading exchange (HNX’s operations, trading rules, and market oversight) was circulated in draft form in early 2025 and remains under revision. Without clear trading rules, companies have no guidance on how to trade allowances or credits, and thus no trades have occurred yet. Additionally, the national carbon registry system – a digital platform to track ownership of carbon credits and allowances – is still being built. The UN Development Programme has been assisting Vietnam in developing this registry, including funding a local IT firm to create a demo system. Until the registry is up and running to issue and track units, authorities are understandably cautious about letting trading begin.

As a result of these factors, the timeline for the ETS pilot’s “active” phase has shifted. Preparations that were initially slated for 2025 have extended into 2026. Recent analyses indicate Vietnam is now aiming to launch the carbon trading platform by late 2026, roughly a one-year delay from the original plan. Full mandatory implementation (with all systems operational and expanded coverage) is still expected by 2029, but the pilot trading period may effectively run from 2026–2028. In the meantime, 2025 has been devoted to establishing the legal framework and building capacity. By late 2025, we see progress: the legal decree (119/2025) is in place, sectoral allocation plans have been drawn up, and technical infrastructure is being put together. The next milestone will be distributing the initial allowances by Dec 31, 2025, as planned, which will mark the point where companies know their emission limits and can begin trading if the platform is ready.

Looking ahead, officials are intent on getting the HNX carbon trading exchange and registry fully functional in 2026. They acknowledge that clear trading guidelines and MRV enforcement rules must be rolled out alongside the allocations. The Ministry of Finance is leading the finalization of the trading platform decree, and once that is issued (likely in 2026), it will pave the way for the first trades of carbon credits/allowances in Vietnam. Despite the slow start, Vietnam’s step-by-step approach may ultimately bolster confidence: by ensuring the “rules of the game” (registry, oversight, accounting) are robust before trading starts, the market can avoid early missteps and gain credibility.

Offsetting Provisions and Proposed Changes

One distinctive feature of Vietnam’s ETS pilot is the generous use of carbon offsets allowed for compliance. As noted, companies can meet up to 30% of their emissions obligation by purchasing carbon credits (emission reductions or removals) from approved projects. These credits can come from domestic projects or international mechanisms, as long as they meet Vietnam’s standards (for example, credits under Article 6 of the Paris Agreement, the Clean Development Mechanism transitioning to Article 6.4, or the Japan–Vietnam Joint Crediting Mechanism are eligible). All offset usage must be transacted through Vietnam’s national registry and the future Carbon Trading Exchange to ensure proper accounting. Notably, the 30% offset limit is higher than what was originally planned – early drafts of the policy only allowed 10%, then 20% offsetting, but the cap was raised to 30% in the final decree after feedback from stakeholders who wanted more flexibility. This means a significant portion of emissions can be neutralized via credits, potentially lowering compliance costs for companies (especially if credits from forestry or clean energy projects are cheaper than cutting emissions or buying allowances outright).

However, discussions are already underway about tightening the offset rules in the future. A Vietnamese policy study released in late 2025 recommends gradually reducing reliance on offsets as the carbon market matures. The study proposes a three-phase roadmap for offset limits and international credit use:

Phase 1 (Pilot 2025–2028): Maintain the current rule allowing up to 30% offsets for compliance. For any carbon credits sold to international buyers (through bilateral agreements under Article 6), Vietnam should retain 50% of those credits to count toward its own national climate targets. In practice, this means if Vietnam generates credits from emission cuts, at least half must stay domestically (or be deducted from its NDC) rather than selling everything abroad – a safeguard against “overselling” reductions and jeopardizing Vietnam’s ability to meet its Nationally Determined Contribution (NDC) goals.
Phase 2 (Post-2028, leading into full ETS): Once measurement, reporting, verification systems and market institutions are fully in place by 2029, tighten the offset limit to 20% of emissions. At this stage the ETS would presumably have a stronger price signal (with some auctioning introduced) and companies should begin cutting more emissions directly. International credit transactions would still keep a 50% domestic retention – meaning Vietnam continues to hold back half of any credits it sells internationally – to ensure consistency between domestic and international markets. The overall emissions cap (or intensity benchmarks) would also be adjusted to align with more ambitious climate targets (including the conditional aspects of Vietnam’s NDC).
Phase 3 (2030 onward): As Vietnam’s carbon market fully integrates its highest climate ambitions (net-zero by 2050, Just Energy Transition Partnership goals, etc.), the study suggests reducing the offset usage limit further to 10% of emissions. By this time, Vietnam’s industries should be doing the bulk of emission cuts internally. Interestingly, the study also advises that after 2030 Vietnam could lower the percentage of credits it must retain domestically to 30%, allowing up to 70% of credits to be exported in international trades. The rationale is that by then Vietnam’s own targets will be much tighter (so fewer “excess” credits available), and any revenue from selling credits abroad should be strategically reinvested in hard-to-abate sectors and a “just transition” for workers and communities. In essence, the proposed long-term strategy is an integrated carbon market approach: start with caution (high domestic retention of credits and ample offsets to ease in participants), then progressively ratchet up stringency to ensure real domestic emissions cuts, while balancing economic feasibility and climate integrity.

It’s important to note that these are recommendations from experts; the government has not yet formally adopted these changes. But they signal a recognition that the current 30% offset allowance, while helpful for the pilot, might be pared back in later years to drive deeper emissions reductions within Vietnam. In the near term, Vietnam is already making rules to ensure any use of international credits adheres to Paris Agreement accounting. For example, the draft regulation on international carbon trading will require issuance of “Letters of Authorization” (LoA) for projects – only credits with an LoA (which triggers a corresponding adjustment to Vietnam’s emissions accounting) can be sold as Internationally Transferred Mitigation Outcomes (ITMOs) abroad. This is to prevent double counting of emissions reductions (i.e. once a credit is exported and used by another country or a foreign company, Vietnam will not count that reduction toward its own NDC). Such measures align with Article 6 rules and underscore Vietnam’s intent to avoid the pitfalls of offset markets while still leveraging them for finance and flexibility.

Linking with Global Carbon Markets and New Initiatives

Vietnam’s carbon market is being designed with an eye toward eventual integration with international carbon pricing mechanisms. During the pilot (2025–2028), trading is restricted to the domestic market – allowances/credits can be exchanged among Vietnamese entities, and there is no linking or sales to foreign entities in the ETS itself. (This is why any foreign involvement comes only via project credits under bilateral deals, not through the ETS directly.) Starting in 2029, Vietnam plans to expand and link its carbon market internationally. In fact, the government has already approved a roadmap to connect with regional and global carbon markets after 2030.

Several steps in 2025 indicate movement on this front:

Bilateral Agreements (Article 6.2): Vietnam has signed cooperation agreements on carbon credit trading with Singapore, Japan, and South Korea. These are part of Article 6.2 of the Paris Agreement, allowing countries to trade carbon reductions. For instance, Vietnam and Singapore inked an MOU to pilot carbon credit transfers, and Vietnam is negotiating with other partners as well. These deals enable Vietnam to sell certain emission reductions to those countries (often to help them meet climate targets) in exchange for investment or other support. Vietnam is proceeding carefully – as mentioned, it’s considering limits like the 50% retention to ensure it doesn’t sell more credits than is wise for its own goals. Still, these partnerships (with advanced economies) could bring in climate finance and technical expertise.
Japan’s Joint Crediting Mechanism (JCM): Japan and Vietnam have been collaborating under the JCM, which finances low-carbon projects in Vietnam and credits the generated reductions to Japan (with shared benefits). In July 2025, a forum was held in Hanoi on “Promoting Business Engagement in the JCM towards readiness for Vietnam’s carbon market,” co-hosted by MAE and Japan’s Ministry of Environment. Japan has been a key partner – Vietnam has 23 approved JCM methodologies (the second most of any country after Indonesia), reflecting active project development. This cooperation not only reduces emissions in Vietnam (through technology investments) but also prepares Vietnamese entities for participation in carbon markets and familiarizes officials with international credit accounting.
South Korea and Carbon Market Linkages: In August 2025, Vietnam hosted a series of meetings with Ecoeye, a South Korean carbon market company, to learn from Korea’s ETS experience. Korean experts provided capacity building to Vietnam’s Department of Climate Change and HNX on running a carbon market, and discussions touched on the possibility of linking the two countries’ markets after 2030. South Korea has Asia’s first national ETS, so its lessons (e.g. dealing with overallocation and low trading liquidity) are valuable for Vietnam. By maintaining dialogues with Korea, Vietnam hopes to eventually create a more interconnected carbon market in the region, which could improve market liquidity and stability in the long run.
Forestry and the Voluntary Carbon Market: Vietnam is also positioning itself as a supplier of forest carbon credits, which could be sold internationally or used domestically for offsetting. With around 15 million hectares of forests, Vietnam sees big potential in nature-based credits. However, issues around additionality and verification of forest projects have historically limited their scale. In mid-2025, the government released the first draft of a decree on forestry carbon credit management. This forthcoming regulation (expected to be finalized by early 2026) will establish rules for generating, verifying, and trading forest-based carbon credits. One important aspect is that MAE will issue the aforementioned LoAs for any forest project that wants to sell credits abroad as ITMOs, to ensure proper accounting. Domestically, Vietnam has already done a notable forest carbon deal: in 2023, it sold 10.3 million tons of CO₂ emission reductions from a REDD+ forestry program to the World Bank for about $51.5 million. Moving forward, having a clear legal framework will likely boost confidence for both domestic project developers and international buyers interested in Vietnamese forest credits. The post-COP30 climate policy workshop in November 2025 highlighted that high-quality credits (especially forest credits) are gaining strategic importance, and Vietnam intends to prioritize credits that represent real, verified, permanent emission reductions. This aligns with new global standards under Article 6.4, which demand greater transparency and integrity for carbon credits.

Overall, Vietnam’s approach to international market linkage is gradual and quality-focused. Officials have stated that Vietnam will “not pursue the volume of low-priced credits, but will prioritize credit quality to protect national interests and enhance international credibility.” This means Vietnam is wary of simply becoming an exporter of cheap carbon credits; instead, it wants to ensure any credit sales bring real benefits and that it keeps enough mitigation at home to meet its own targets. The groundwork being laid in 2025 – from Article 6 collaborations to draft regulations for trading and credit quality – shows Vietnam gearing up to be a serious player in carbon markets while safeguarding its NDC commitments.

Building Capacity and Stakeholder Engagement

Because an emissions trading scheme is new to Vietnam, extensive efforts are underway to educate and involve stakeholders across government, industry, and civil society:

Government Training and Staffing: Within ministries, new units and teams have been formed (or existing ones expanded) to handle carbon market implementation. The Department of Climate Change (DCC) under MAE is leading technical work on the ETS. Staff have participated in capacity-building workshops with international experts (like the South Korea and Japan exchanges mentioned above) to learn about cap-and-trade mechanics, registry operation, and enforcement. These trainings are crucial for Vietnam to administer the market effectively. The Partnership for Market Implementation (PMI) and other programs are likely supporting Vietnam with technical assistance as well.
Industry Outreach: As noted, many covered companies initially lacked experience in carbon accounting. To bridge this gap, Vietnam, often with help from development partners, has rolled out training courses and simulations for companies. For example, the Institute of Strategy and Policy on Natural Resources and Environment (ISPONRE), with partners like the World Bank and UNDP, organized simulation exercises on how an ETS works. In August 2025, a training session co-hosted by EuroCham and the World Resources Institute gathered industry representatives to discuss Decree 119 and remaining questions on allowance allocation and MRV. These sessions reveal that while businesses generally support the idea of an ETS, they still have questions and confusion – e.g. how exactly their allocations will be determined, what monitoring standards they must meet, and when carbon price signals (like credit auctions or trading) will really kick in. The dialogue has been ongoing, and the government is using feedback to refine guidelines. Crucially, the survey by the Energy Transition Partnership showed a “strong consensus” among companies that more government-led capacity building is needed. We can expect continued workshops and guidance documents so that by the time compliance obligations are enforced (the first true compliance check likely after 2026 for 2025 emissions), companies will know how to measure and, if needed, trade to cover their emissions.
Public and Environmental Groups: Vietnam is also bringing academia and civil society into the conversation. The November 2025 “Navigating global and Vietnam’s carbon market post-COP30” workshop in Hanoi is a good example. It brought nearly 200 domestic and international participants, including university experts, NGOs like CIFOR (Center for International Forestry Research), and foreign diplomats. Topics ranged from the Article 6 rulebook coming out of COP30 to how to ensure social equity in carbon markets. For instance, representatives from CARE Vietnam emphasized that social equity must be at the heart of carbon market development, ensuring that women, low-income communities, and ethnic minorities can participate and benefit. This reflects a broader commitment in Vietnam’s climate action to the principle of “leave no one behind.” We are seeing early thinking about using carbon market revenues or projects to support sustainable development in local communities, which can help build public support for climate policies.
Financial and Technical Infrastructure: On the practical side, capacity building includes setting up the registry and exchange software, training local IT personnel, and establishing protocols for verifying emissions. By late 2025, a demo version of the national registry is reportedly in testing. The Hanoi Stock Exchange, which already handles stock and bond trading, is training its staff and upgrading systems to handle carbon units – a new asset class. Vietnam’s Securities Depository (VSD) is also involved in ensuring the traceability and integrity of carbon credits in the market. All these preparations aim to make the carbon market as robust and credible as the country’s financial markets.

In summary, Vietnam recognizes that setting up an ETS is as much an institutional and educational project as it is a policy project. The success of the scheme will depend on how well companies understand and engage with it, and how effectively the government can monitor and enforce the rules. So far, the groundwork in 2025 has been about building this foundation – training people, creating systems, and refining laws – to ensure the ETS can operate smoothly and fairly in the years ahead.

Next Steps and Outlook

As 2025 closes and Vietnam moves deeper into the ETS pilot phase, several important milestones and developments are on the horizon:

Allocation of 2025–2026 Allowances: By the end of December 2025, MAE is expected to finalize and distribute the emissions allowances for each covered installation for the first compliance period. This will effectively kick-start the clock on the pilot ETS – companies will know their emission “budgets” and can strategize accordingly. If a company anticipates emissions above its allocation, it will need to plan to procure offsets or allowances from others; if below, it might bank the unused allowances (allowed through 2030) or potentially sell them once trading begins.
Inaugural Carbon Market Trades: Assuming the trading platform and registry become operational, Vietnam could see its first carbon credit trades in late 2025 or early 2026. Regulators had initially hoped for a maiden trade by the close of 2025. Even if that slips to 2026, it will be a symbolic moment – likely a state-owned company or utility making the first transaction on the HNX carbon exchange. Early trading will probably be limited in volume, especially since all allowances are free (companies might not feel an urgent need to trade). However, some firms that are short of allowances may begin buying credits (e.g., a thermal power plant purchasing forestry credits to cover a portion of its emissions). Likewise, any company that can easily beat its intensity benchmark might have surplus allowances to sell. The government will be closely watching these initial trades to glean price signals that could inform future policy (such as the level of overallocation or scarcity in the system).
Mid-Pilot Reviews: Vietnam has built into its framework a process to periodically review and update the list of regulated sectors and facilities. Every two years, MAE will propose updates to the Prime Minister on which sectors/firms should conduct GHG inventories and be subject to the ETS. So by 2026–2027, we might see an adjustment – potentially adding more large emitters or new sectors (like transport or waste) into the fold on a pilot basis. The 2020 Environmental Protection Law and Decision 232/QD-TTg (Jan 2025) already envisage expanding the carbon market’s scope in phases. Stakeholders will also evaluate how well the intensity-based caps are working; if emissions are not trending as desired, the government could tighten the benchmarks or lower the cap trajectory even before 2029.
Legislation to Watch: Several important regulations are slated for completion in 2026. These include the decree on carbon trading operations (HNX rules), the forestry carbon credit decree, and rules on international credit exchanges. By incorporating outcomes from COP30 (held in late 2025) into these laws, Vietnam will ensure its carbon market aligns with the latest global standards. For example, decisions made at COP30 about Article 6.4 governance or credit tracking will be reflected in how Vietnam manages corresponding adjustments and credit quality. The completion of these laws will mark the transition of Vietnam’s carbon market framework from “pilot design” to a more comprehensive regulatory system.
Expansion in 2029 and Beyond: The pilot ETS is scheduled to run until the end of 2028, after which Vietnam’s carbon market enters a new phase. From 2029 onward, the country aims to have a fully operational ETS that could include auctioning of allowances (introducing government sales of permits to generate revenue and create a clearer price signal). Sectoral coverage is also expected to expand by 2029 – for instance, Vietnam has indicated it will bring in the transportation sector (like aviation, shipping or road freight) and commercial buildings into the carbon market at that time. Integrating these sectors will raise new challenges (e.g., how to measure and cap emissions from hundreds of commercial buildings or vehicles), but work is likely to begin well before 2029 to set the methodologies. By the early 2030s, Vietnam also foresees linking its market internationally, which could mean allowing foreign entities to buy/trade Vietnam’s carbon units or vice versa. This would make Vietnam part of a larger Asia-Pacific carbon market network, potentially connecting with systems in countries like South Korea, China, or even a future ASEAN carbon mechanism.
Climate Goals and Finance: In parallel with the ETS, Vietnam continues to advance other climate initiatives. At the Autumn Economic Forum 2025 and COP30, Vietnam reiterated that achieving net-zero by 2050 remains a firm national goal, but also candidly noted the need for significant investment (tens of billions of dollars) for the green transition. A well-functioning carbon market can help attract some of this finance by monetizing emission reductions. For example, revenues from any allowance auctions post-2029 could be funneled into clean energy projects or just transition funds. Vietnam is also working on complementary policies like the JETP (Just Energy Transition Partnership) to phase down coal with international support, and considering a carbon fee or tax on large emitters (the Ministry of Finance has drafted proposals on environmental fees for emissions). The ETS will thus operate in an ecosystem of climate policies and economic measures aimed at steering Vietnam onto a lower-carbon development path.

In conclusion, since the ETS pilot’s launch in mid-2025, Vietnam has made steady progress in laying the groundwork for a credible carbon market. Key achievements include establishing the legal framework (Decree 119 and related decisions), defining the scope and rules of the pilot, and engaging both domestic and international stakeholders in capacity building. While initial trading has been delayed as Vietnam finalizes technical details, this cautious approach is building confidence that when trading does start, it will be on solid footing. The coming year (2026) is poised to be transformative: we expect the first trades and price discovery, more concrete data on emissions versus allowances, and possibly the first signs of emissions peaking in the covered sectors as companies respond to the new regulations. By 2028, Vietnam will have a few years of ETS experience under its belt, ready to scale up to a more ambitious, broader carbon market.

Vietnam’s journey with emissions trading is just beginning, but it reflects a broader trend in developing Asia – using market mechanisms to align economic growth with climate sustainability. With continuous updates (like the ones in late 2025 on offset policies and international cooperation), Vietnam is showing adaptability and commitment to making its carbon market an effective tool. As one official put it, Vietnam views the carbon market “not merely as a trading platform, but as a powerful lever to drive a low-emissions growth model”. The latest developments in 2025 demonstrate that this lever is being carefully calibrated for the challenges and opportunities ahead.

Sources: Vietnam government and news outlets, including Reuters, S&P Global, MAE (Ministry of Agriculture and Environment) releases, and climate policy analysts, among others.

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