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Sustainability Reporting Requirements in Vietnam

Keslio Team
 minute read  
March 19, 2024
A violet monochromatic illustration of mountains and rice fields in Vietnam.

History of Sustainability Reporting in Vietnam

With governments and organizations making commitments towards sustainability and climate change, businesses face great challenges and responsibilities in achieving their own targets. In the journey of sustainable development, a key factor that now plays a major role in the success of a business is sustainability reporting, with stakeholder demands and regulations being passed requiring publicly listed companies to submit annual sustainability reports.

Vietnam has made commitments towards sustainability. In 2012, the Vietnam Sustainable Development Strategy for 2011-2020 was signed. The strategy included ESG targets, priorities for the decade, solutions, and involved organizations. Additional targets were made in 2021. By 2030, they aim to stop deforestation and reduce Greenhouse Gas emissions. Vietnam also plans to phase out coal-fueled power generation by 2040. Lastly, the country aims to have net-zero carbon emissions by 2050.

To strengthen sustainable development, Vietnam’s Ministry of Finance issued Circular 155/2015/TT-BTC in 2015, which provides guidelines on information disclosure on the securities market. This includes guidelines on financial reporting and also for sustainability reporting. Eventually, the Ministry of Finance replaced this with Circular 96/2020/TT-BTC, increasing the scope of disclosure. In sustainability reporting, this is currently mandatory for publicly listed companies.

Sustainability Reporting

ESG reporting as a mandatory requirement for listed companies was implemented in Vietnam since 2016. In the latest circular, which was implemented in 2021, sustainability reports are required to be submitted by Vietnamese publicly listed companies.


To be included in a company’s annual report are sustainability performance-related disclosures. Circular 96 points out requirements which can be split between environmental and social performance disclosures. These requirements or disclosure indicators consist of the following: Materials, Energy, Water, Compliance, Organizational Profile and Market Presence, Employment, Occupational Health and Safety, Training and Education, Local Community, and Green Capital Market Activities.

For environmental disclosures, companies must disclose the environmental impact their business has. This includes information on indirect and direct greenhouse gas emissions and initiatives the company has to further reduce emissions. Water consumption, and indirect and direct energy consumption is also included in the report. Companies also should disclose energy efficiency programs or activities the business undertakes and report how much energy was saved.

Raw materials and waste management is also to be reported. Information related to these include the amount of raw materials used to manufacture and package products and services. Included as well are percentages of materials recycled to develop the company’s products and services.

Lastly, companies must also disclose their compliance with environmental protection laws. If the company was unable to comply, fines received by the business are also disclosed.

For social performance reports, companies must report information regarding employee performance and metrics. For metrics, this includes employee count and average wages. Policies and programs catered to employee well-being are included, such as health and safety policies and skills training programs.

Social performance reports also extend to the company’s engagement and involvement with communities, ranging from community investments, development programs and activities, and financial aid.

Green capital market activities under the guidance of the State Securities Commission (SSC), an organization under the Ministry of Finance of Vietnam are included in the report for financial institutions only. Financial institutions must disclose green financing programs and a percentage of total investments that may fall under the category.

Lastly, the company’s board of directors are also to provide an assessment report related to the company’s environmental and social responsibilities. The sustainability report also includes corporate objectives towards ESG.


The State Securities Commission, alongside the International Finance Corporation (IFC), a member of the World Bank Group developed the Environment and Social (E&S) Disclosure Guide in 2016, which aims to provide additional guidance for companies in Vietnam to comply with ESG reporting requirements. The guide aims to help businesses better understand the complex world of sustainability reporting through providing a basic and simple methodology companies can use as a foundation for measuring sustainability performance. The guide is based on the G4 Reporting Principles of the Global Reporting Initiative (GRI). For other globally accepted standards, the use of these in sustainability reporting is encouraged. PwC’s Sustainability Counts II Report 2023 shows that the ISO, GRI, and SDG standards were the top three used in 2022 [1].

In the E&S Disclosure Guide, the SSC provides the following simple four-step process companies can use as a starting point:

  1. Determine scope of report
  2. Calculate and collect data
  3. Review data
  4. Disclose data

When it comes to materiality and disclosure indicators, the guide lists what kind of metrics to report and how to disclose these metrics, even providing sustainability report examples for each requirement. Each disclosure indicator also includes disclosure references, aligning the requirements to other current laws and regulations in the country.

It is important to note as well that some indicators are not mandatory for certain sectors and industries. For example, companies in the finance, banking, securities and insurance sectors are not mandated to disclose performance on raw materials, energy, and water. In addition, green capital market activities disclosures are required for financial institutions only.

The E&S Disclosure Guide also provides an example of a disclosure template to help guide companies in explaining their performance. Companies are to indicate the level of disclosure for each indicator. The levels are as follows:

  1. Full Disclosure (FD)
  2. Partial Disclosure (PD)
  3. No Information (NI)
  4. Not Applicable (NA)

The E&S Disclosure Guide helps companies kickstart their sustainability reporting initiatives, giving clarity towards what to disclose and also helping pave the way for companies to create strategies and processes dedicated to ESG data collection and continuous improvement.

Future of Sustainability Reporting in Vietnam

Vietnam continues to progress towards stronger sustainability reporting as a means of achieving their sustainable development goals. Workshops have been previously conducted by the Hanoi Stock Exchange, Ho Chi Minh City Stock Exchange, and other government agencies and international institutions to empower companies and train them in ESG reporting. Recently, in 2022, a workshop was conducted to train companies in understanding and developing climate-related financial disclosures aligned with TCFD recommendations.

Opportunities lie ahead for Vietnam and their sustainable development goals. In reporting, adopting globally accepted standards and responding to current reporting trends may further enhance sustainability reporting as it may provide more insight for both the company and its stakeholders.

Sustainability reporting is a continuously improving practice and identifying key improvements can help advance companies in achieving their sustainability commitments and push the country towards a stronger future.


[1] PwC Sustainability Counts II Report 2023

At Keslio, we are deeply passionate about sustainability, equipping us with the expertise and extensive network needed to guide clients through their sustainability journey effectively and efficiently. Our expertise is particularly valuable for companies looking to embed sustainability practices into their businesses and investors looking to integrate ESG and impact into investment portfolios. To learn more about how Keslio can assist your organization on its sustainability journey, please don't hesitate to get in touch with us.

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