Last updated: May 2026. Vietnam sustainability reporting requirements are not a single standalone ESG law. For many companies, the core obligation comes through securities-market disclosure rules: public and listed companies prepare an annual report that includes environmental, social, and governance information. For large emitters, Vietnam's greenhouse gas inventory and mitigation rules create a separate compliance track.
Short answer: Public and listed companies in Vietnam should check Circular 96/2020/TT-BTC and the annual report template in Appendix IV. The sustainability content normally covers greenhouse gas emissions, raw materials, energy, water, environmental compliance, employees, local community responsibility, and green capital market activities where relevant. Separately, facilities that meet Vietnam's greenhouse gas inventory thresholds or appear on the Prime Minister's facility list may need facility-level GHG inventory reporting under Decree 06/2022/ND-CP and its amendments.
Who needs to report sustainability information in Vietnam?
The main sustainability reporting obligation applies through Vietnam's securities disclosure regime. In practice, this means the first question is whether the company is a public company, a listed company, or otherwise subject to securities-market annual report requirements.
Circular 96/2020/TT-BTC replaced Circular 155/2015/TT-BTC and remains the central reference for information disclosure on the securities market. It is not a blanket requirement for every private company in Vietnam. A private company that is not within the securities disclosure regime may still face sustainability data requests from investors, lenders, customers, or parent-company reporting programs, but those should be assessed separately from the Circular 96 annual report obligation.
A second question is whether the company or facility is covered by Vietnam's greenhouse gas inventory rules. These rules are not limited to listed companies. They focus on sectors and establishments with significant emissions, energy consumption, fuel consumption, or waste treatment capacity.
What Circular 96 asks companies to disclose
Circular 96 requires covered companies to prepare annual reports using the prescribed annual report form. The sustainability-related content is practical rather than abstract. Companies should be ready to explain performance and management actions across environmental and social topics, not just publish a broad statement about ESG commitments.
The annual report sustainability section commonly includes:
- direct and indirect greenhouse gas emissions, together with measures or initiatives to reduce emissions;
- raw material use, including total materials used for products, packaging, and services, and the share of recycled materials where applicable;
- direct and indirect energy consumption, energy savings, and energy-efficiency initiatives;
- water supply, water use, and recycled or reused water where relevant;
- compliance with environmental protection law, including fines or sanctions where applicable;
- employee information, wages, health and safety, welfare, training, and skills development;
- community investment and local community development activities; and
- green capital market activities under State Securities Commission guidance where relevant.
For finance, banking, securities, insurance, and similar sectors, some operational indicators such as raw materials, energy, and water may require a different relevance check than they would for manufacturing, logistics, real estate, or heavy industry. The point is not to force every company into the same template mechanically. The point is to map the required indicators to the company's actual operations, evidence, and annual report disclosure needs.
Why the annual report timing matters
Vietnam's annual report process is tied to the company's wider financial reporting cycle. Covered companies should not treat ESG data collection as an end-of-year writing exercise. Energy, water, fuel, waste, employee, safety, community, and compliance data often sit across finance, facilities, operations, HR, legal, and EHS teams. If those teams wait until the annual report is already being drafted, the sustainability section becomes harder to evidence and more likely to contain gaps.
A practical approach is to build a reporting pack during the year: define each indicator, assign an internal owner, collect supporting documents, and keep a short methodology note explaining how each number was calculated.
GHG inventory obligations are a separate check
Vietnam's climate reporting framework sits alongside the securities disclosure regime. Decree 06/2022/ND-CP sets rules on greenhouse gas emissions mitigation, greenhouse gas inventory, measurement, reporting, verification, and the carbon market. It has since been amended, including by Decree 119/2025/ND-CP and subsequent updates.
Under Decree 06, an establishment may be subject to greenhouse gas inventory if it emits at least 3,000 tCO2e annually or meets specified energy, fuel, commercial-building, or solid-waste thresholds. The Prime Minister's updated facility list is also important. Decision 13/2024/QD-TTg updated the sectors and facilities subject to greenhouse gas inventory, including energy, transport, construction, industrial processes, agriculture, forestry and land use, and waste.
For affected facilities, the GHG inventory process is more technical than the annual report ESG section. It requires activity data, emission factors, calculation boundaries, methodology documentation, internal review, and submission through the relevant government process. For companies that are both listed and covered by GHG inventory rules, the two workstreams should be connected but not confused: the annual report disclosure explains sustainability performance to investors, while the inventory report follows the climate-regulation process.
What companies should prepare
Before drafting a Vietnam sustainability report, companies should build a simple compliance map. This avoids two common mistakes: writing a generic ESG narrative that misses required indicators, or starting a full GRI-style report when the immediate requirement is a Circular 96 annual-report section.
A useful preparation checklist includes:
- confirm whether the company is covered by Circular 96 annual report requirements;
- check whether any Vietnam facilities are listed or threshold-triggered under the GHG inventory rules;
- map Circular 96 indicators to internal data owners across finance, operations, HR, EHS, legal, and facilities;
- collect energy, fuel, water, materials, waste, compliance, employee, safety, training, and community records;
- calculate Scope 1 and Scope 2 emissions where the company reports GHG emissions, and assess whether relevant Scope 3 data is needed for investor or customer expectations;
- document calculation methods, emission factors, assumptions, exclusions, and data limitations;
- review whether sector-specific indicators are relevant, not applicable, or need explanation; and
- prepare a concise management review before the annual report is finalized.
Common reporting mistakes
The most common problem is treating sustainability reporting as a communications project only. Good writing matters, but the report needs a data backbone. If the company cannot explain where energy, water, emissions, employee, and compliance numbers came from, the report will be difficult to defend with investors, auditors, customers, or regulators.
A second mistake is mixing up company-level ESG disclosure with facility-level GHG inventory. A listed company may need an annual report sustainability section even if it is not on the GHG inventory list. A high-emitting facility may need inventory reporting even if the parent company is not listed. Some groups may need both.
A third mistake is copying international standards without first checking the local requirement. GRI, IFRS sustainability standards, TCFD-style climate disclosure, and customer questionnaires can all be useful, but they should be layered onto the Vietnam requirement rather than replacing it.
How Keslio can help
Keslio supports companies that need to turn Vietnam sustainability reporting requirements into a clear reporting plan, evidence pack, and finished disclosure. Our work can include:
- reviewing whether the company appears to fall under Circular 96, GHG inventory rules, investor reporting, or customer-request reporting;
- building a reporting checklist and data request by function;
- supporting GHG emissions calculations, including Scope 1 and Scope 2 where relevant;
- preparing methodology notes, assumptions, and evidence trackers;
- drafting or improving annual-report sustainability content through our reporting and communications support; and
- helping suppliers respond when customers ask for Vietnam-linked emissions or sustainability data through supplier request support.
If you are preparing a Vietnam annual report, responding to investor ESG questions, or checking whether a facility-level GHG inventory obligation applies, the best first step is to review the exact reporting trigger and data requirement before calculating anything.
