Vietnam GHG, CBAM & Carbon Market Compliance Calendar 2026–2030

The three biggest deadlines ahead are: 31 March 2027, when facilities file their GHG inventory report (2025–2026 data) and their first emission reduction report with the provincial People's Committee; 30 September 2027, the first CBAM declaration in the EU; and 31 December 2027, when the 110 thermal power, steel and cement facilities must surrender their VN2025 allowances. Failing to submit an inventory report draws a warning. Failing to prepare one costs an organisation VND 60–100 million, and the report must still be produced. Those penalties come from Decree 45/2022/ND-CP, which was still in force on 07/10/2026. The full calendar to 2030 follows.

This page is a quick-reference calendar. For the roadmap explained, read Vietnam GHG Inventory Roadmap. For the steps to prepare a report, read GHG Inventory Process in Vietnam 2026.

When is the GHG inventory report due?

Facilities on the Decision 42/2026/QD-TTg list (2,441 facilities, in force from 25/09/2026) file a facility-level inventory report with the provincial People's Committee before 31 March, every two years. The next filing is due before 31/03/2027 and covers 2025 and 2026. The legal basis is Article 11(4)(b) of Decree 06/2022/ND-CP, as amended by Decree 119/2025/ND-CP.

Thermal power, steel and cement facilities that receive allowances follow separate rules (Article 11(4)(c) and 11(6a)). They prepare an inventory every two years from 2026 and send a verified report to the Ministry of Agriculture and Environment (MAE) before 1 December, starting in 2027. The 31 March inventory filing with the province does not apply to them. They must still file the annual emission reduction report.

Compliance planning inside a company

Compliance calendar 2026–2030 by date

The table covers inventory, emission reduction reporting, the domestic carbon market and EU CBAM. "Facilities" means facilities on the mandatory inventory list. "110 facilities" means those allocated allowances for 2025–2026.

* Date derived from a rule in the decree (biennial inventory due before 31 March; surrender before 31 December of the year after the allocation period), not a date stated explicitly in the text.

Figure 1: Timeline of GHG inventory, carbon market and CBAM compliance deadlines from 25/09/2026 to 31/12/2030

What is the penalty for not submitting a GHG inventory report?

Current penalties are set by Article 45 of Decree 45/2022/ND-CP on administrative sanctions in environmental protection, in force since 25/08/2022. The amounts in the decree apply to individuals. Under Article 6(2), organisations pay double.

The limitation period for administrative sanctions in environmental protection is two years. The fines themselves are small next to the cost of preparing a report. The larger risks lie elsewhere: you are still forced to prepare reports for every missing year, reports can be sent back for rework during verification, and data may lack supporting documents. For the 110 facilities, there is also the risk of having the shortfall deducted from the next allocation.

Legal status of the penalties (updated 07/10/2026)

• Decree 45/2022/ND-CP: in force. As of 07/10/2026 we found no replacement decree issued.
• Draft decree replacing Decree 45/2022: in preparation. According to Sài Gòn Giải Phóng (06/06/2026), the draft had been sent to the Ministry of Justice for appraisal and was expected to go to the Government in June 2026. Published changes focus on waste, producer recycling responsibility and environmental impact assessment. No new GHG or allowance penalties have been published.
• Under-surrendering allowances: amended Decree 06/2022 says the facility "is sanctioned under the law on administrative sanctions" and the shortfall is deducted from its next allocation. We have not identified a specific fine for this violation in the current Decree 45/2022.
• Law on Environmental Protection (amended): still a draft. According to Báo Chính phủ (30/09/2026), Deputy Prime Minister Hồ Quốc Dũng proposed keeping the two-year inventory frequency rather than moving to annual reporting. This calendar will be updated if the National Assembly adopts a change.

Figure 2: Penalty table under Decree 45/2022/ND-CP: failing to submit draws a warning; failing to prepare costs an organisation VND 60–100 million

Which CBAM deadlines affect Vietnamese exporters?

CBAM entered its definitive phase on 01/01/2026, covering steel, aluminium, cement, fertilisers, hydrogen and electricity. The legal obligation sits with the EU importer. But the importer needs verified emissions data from the Vietnamese plant, and without it must use default values that carry a mark-up. The key dates:

• 01/02/2027: certificate sales open on the common platform. 2026 prices are published quarterly: EUR 75.36 (Q1), EUR 75.28 (Q2) and EUR 82.32 (Q3). From 2027, prices are published weekly.
• 30/09/2027: the first declaration, for 2026 imports, then every 30 September after that. Surrendering too few certificates costs EUR 100 per tCO₂e, indexed to the European consumer price index, and the missing certificates must still be surrendered. Importing without authorisation is penalised at three to five times that level (according to DEHSt, Germany's CBAM authority).
• 50-tonne threshold: importers below 50 tonnes a year are exempt under Regulation (EU) 2025/2083.

For detail, see CBAM 2027: What Vietnamese Exporters Need to Do.

Domestic carbon market: which deadlines apply to the 110 facilities?

For the 110 thermal power, steel and cement facilities, 2027 brings three deadlines close together: the verified inventory report to MAE before 1 December, the last VN2025 trading day on 24 December, and surrender before 31 December. Because the gaps are so short, emissions data should be finalised by October 2027 to leave time for verification. A facility short of allowances has three ways to close the gap: buy on the exchange, borrow up to 15% from its own next-period allocation, or offset up to 30% with carbon credits. For background, see 2025–2026 emission quota allocation and Vietnam's carbon exchange.

What should companies do each quarter until 31 March 2027?

Next step: check your obligations with the free lookup tool, then talk to us about the GHG inventory service to meet the 31/03/2027 deadline. If you export to the EU, see the CBAM reporting service.

Frequently asked questions

When is the 2027 GHG inventory report due?

Before 31/03/2027, filed with the provincial People's Committee and covering 2025 and 2026. Facilities with allowances send a verified report to MAE before 01/12/2027.

When is the annual emission reduction report due?

Before 31 March each year, starting in 2027. It covers the previous year, uses Form 02 of Appendix III to amended Decree 06/2022, and goes to the provincial People's Committee.

What is the penalty for not submitting a GHG inventory report?

Not submitting: a warning. Not preparing the report: VND 60–100 million for an organisation, plus a duty to prepare it. Inaccurate or incomplete data: VND 10–20 million for an organisation. The basis is Decree 45/2022/ND-CP, still in force as of 07/10/2026.

Are penalties about to change?

A decree to replace Decree 45/2022 is being drafted but had not been issued as of 07/10/2026. No new GHG penalties have been published.

When must VN2025 allowances be surrendered?

Before 31/12/2027, in the National Registry. The last VN2025 trading day is 24/12/2027.

When is the first CBAM declaration due?

Before 30/09/2027, for goods imported into the EU in 2026. The EU importer files the declaration and surrenders the certificates, but needs emissions data from the exporter.