Vietnam GHG Inventory Roadmap Under Decree 06/2022 & 119/2025 [2026]

Under Decree 06/2022/ND-CP (as amended by Decree 119/2025/ND-CP, effective 1 August 2025), facilities on the list of entities required to conduct a greenhouse gas (GHG) inventory must submit a facility-level inventory report every 2 years, before 31 March, starting with 2024 data; from 2027 they must also submit an annual emissions mitigation report. This article sets out the full roadmap milestone by milestone, together with a preparation checklist for businesses.

Which businesses must conduct a greenhouse gas inventory?

Facilities required to conduct a GHG inventory are those with annual emissions of 3,000 tonnes of CO₂ equivalent or more, or those in one of the following groups: thermal power plants and industrial production facilities consuming 1,000 TOE/year or more of energy; freight transport companies consuming 1,000 TOE/year or more of fuel; commercial buildings consuming 1,000 TOE/year or more of energy; and solid waste treatment facilities with a capacity of over 65,000 tonnes/year. The specific list is issued by the Prime Minister and updated periodically — see details in our article sectors and facilities required to conduct a GHG inventory.

GHG inventory roadmap under current regulations

The table below summarizes the milestones businesses need to remember, based on Decree 06/2022/ND-CP, Decree 119/2025/ND-CP and Decision 263/QD-TTg (9 February 2026):

The biggest change from 2026: the inventory is no longer just a reporting obligation. For facilities that have been allocated allowances, inventory data directly determines whether a facility has a surplus or a shortfall of allowances — directly affecting costs (buying additional allowances/credits) or revenue (selling the surplus). See our analysis in The Government allocates emission allowances for 2025–2026.

Figure 1: Vietnam GHG inventory roadmap 2025–2029: inventory report every 2 years before 31 March, allowance pilot for 110 facilities, 2027 reporting period for 2,441 facilities, annual mitigation report, official carbon market from 2029

What are the steps in a facility-level GHG inventory?

The facility-level inventory process, as guided by the sector-managing ministries (based on ISO 14064-1 and IPCC), consists of 5 main groups of tasks: (1) define organizational and operational boundaries — direct emissions (Scope 1) and indirect emissions from purchased energy (Scope 2); (2) collect activity data: fuel, electricity, steam, technological processes, waste; (3) select emission factors from the national list or IPCC; (4) calculate and aggregate emissions by source; (5) perform data quality control and prepare the report in the prescribed template. We explain each step in detail in our articles 9 steps to conduct your own GHG inventory and Scope 1, 2 and 3 emissions under the GHG Protocol and ISO 14064.

A new point under the Government's requirements for the allowance phase: internal inventory data is no longer enough — facilities must be ready for measurement and verification by an independent body. Data systems therefore need to trace the origin of every figure, rather than relying on a single Excel file compiled at year-end.

An industrial plant subject to GHG inventory requirements

Are there penalties for not conducting a GHG inventory?

Yes. The inventory obligation is mandatory under the Law on Environmental Protection 2020 and Decree 06/2022/ND-CP; failing to submit a report, submitting late or reporting incorrectly may result in administrative penalties under the regulations on sanctions in the environmental sector. The bigger risk than the fine is business risk: a facility without verified inventory data will have no basis when allowances are allocated, will struggle when export customers request emissions data (CBAM, supply chains), and will lose its edge once the carbon market officially launches in 2029.

Preparation checklist for businesses (start today)

Figure 2: 6-item GHG inventory preparation checklist with timing: check the list, appoint a focal point, continuous data collection, trial inventory, standardize the process, track allowances

EcoCheck helps businesses stay ahead of the roadmap

EcoCheck is a GHG inventory platform designed around Vietnam's legal framework: automated inventories using national and international standard emission factors (IPCC, GHG Protocol), monthly/quarterly/annual progress tracking against allowances, and standardized reports ready for third-party verification. EcoCheck's team of experts is ISO 14064-1 certified. Learn about the EcoCheck GHG inventory service or contact us for advice on a roadmap suited to your facility.

September 2026 update: the list of facilities required to conduct an inventory has been officially issued — Decision 42/2026/QD-TTg covering 2,441 facilities, effective 25 September 2026, replacing Decision 13/2024.

Before the 31 March deadline: budget early — see GHG inventory costs & how to read a quote to avoid paying a premium for a rush job.

Don't have the resources to follow the roadmap yourself? Use our GHG inventory service to make sure you meet the deadline and pass verification.