Identifying Green Projects and Projects Meeting Circular Economy Criteria, and Applying the ESG Framework

1. Who this applies to and three key distinctions

This guidance is intended for private-sector enterprises, household businesses and individual business operators covered by Article 2 that wish to have their projects identified as green projects or projects meeting circular economy criteria.

Businesses should distinguish between three related activities:

1. Project determination: assessing the project type, objectives and applicable requirements under Article 3 and Appendix I or Appendix II against project documentation, data and evidence. This determination is carried out by an independent assessment body meeting the requirements of Article 4.
2. Applying the ESG framework: preparing a report on the application of the environmental, social and governance standards framework under Article 5, using the framework in Appendix VI and the reporting template in Appendix VII, and fully implementing the measures set out in the report.
3. Consideration for interest subsidies: the project determination and ESG report provide a basis for considering interest subsidies. Eligibility also depends on the conditions set out in relevant legislation.

References: Articles 2–6 of Decision No. 46/2026/QĐ-TTg; Article 5(5) sets out the basis for considering interest subsidies.

2. Identifying the right project category and criteria

Green projects: reviewing project type, objectives and requirements

Under Article 3(1), green projects are identified based on the project type, objectives and corresponding requirements in Appendix I. Businesses should specify the applicable entry in the Appendix, the scope of the project submitted for determination and the evidence demonstrating fulfilment of each requirement.

An activity that benefits the environment is not sufficient to establish that an entire project is green. For example, a factory with a solar power installation still needs to define the scope submitted for assessment and address all corresponding requirements in Appendix I.

Projects meeting circular economy criteria: identifying the category and corresponding requirements

A project must fall within a category specified in Article 3(3)–(6) and meet the corresponding requirements for its industry, sector or product in Appendix II. The four project categories are:

References: Article 3 and Appendices I–II to Decision No. 46/2026/QĐ-TTg.

3. Preparing documentation and evidence

Under Article 4(3) and (4), the application comprises a written request and a project explanatory report using the corresponding templates issued with the Decision:

Preparing evidence for each explanation

Each explanation of how a criterion is met should have a specific, verifiable and traceable basis. Businesses should maintain a tracking table covering: applicable criterion – explanation – evidence – responsible person – completion status.

Depending on the applicable requirements, the documents and data to prepare may include:

• Project information: ensure that the project name, location, implementing entity, scale, technology, products and scope submitted for determination are consistent across documents.
• Legal, technical and environmental documentation: compile documents appropriate to the project type and stage, such as designs, process flow diagrams, equipment specifications and relevant environmental records.
• Quantitative data: specify data sources, reporting periods, units of measurement, calculation methods and assumptions for indicators relating to resources, energy, raw materials, water, waste or other relevant matters.
• Evidence of circular activities: where required by the criteria, describe flows of raw materials, materials, by-products or waste; reuse, recovery and recycling methods; participating entities; and documents demonstrating collaborative activities.

The list above provides guidance on preparing evidence. The specific documents required should reflect each project’s criteria, scope and actual status; the same set of technical documents does not apply to every case.

4. Selecting an independent assessment body

Under Article 4(1), green projects and projects meeting circular economy criteria are determined through an independent assessment body meeting the requirements of Article 4(2). When selecting a body, businesses should consider:

• Legal status: it must have legal personality and be registered to conduct business in Viet Nam or established by a decision of a competent state authority.
• Type of business or function: it must provide conformity assessment services, have a legally recognised conformity assessment function or provide auditing services.
• Management system and operational competence: it must meet one of the standards specified in Article 4(2)(d): ISO/IEC 17029:2019; Vietnamese Standard on Assurance Engagements 3000; or International Standard on Assurance Engagements (ISAE) 3000. Amendments, supplements or replacement standards apply as provided in that point.

Before signing a contract, businesses should ask the assessment body to clarify its competence in the project’s sector and technology; arrangements for independence and objectivity; scope of work; deliverables; timeframe; and fees.

Steps for working with the assessment body

1. Agree on the scope and submit the application

   Clarify the determination requested, the project scope and the intended use of the results. Prepare the written request using Appendix III, accompanied by the explanatory report under Appendix IV or Appendix V, depending on the type of determination requested.

2. Review documentation and clarify evidence

   The assessment body examines the documentation against the criteria in Article 3 and the relevant Appendix. The business appoints a contact person to provide data, explanations and additional evidence where necessary.

3. Receive the results and review the determination document

   When a project is determined to meet the requirements, the document must contain the information specified in Article 4(6): details of the assessment body and the project implementing entity; scope and scale; a summary of technology and products; the determination of fulfilment of the criteria; requirements to be met and maintained; and any other requirements, where applicable.

Timeframes and fees are agreed between the parties in accordance with relevant legislation. The Decision does not prescribe a uniform fee or assessment timeframe for all projects.

References: Article 4 of Decision No. 46/2026/QĐ-TTg. The coordination steps above are suggested arrangements to help businesses organise implementation.

5. Preparing reports and applying the ESG framework

Enterprises, household businesses and individual business operators implementing green projects or projects meeting circular economy criteria must prepare a report on the application of the environmental, social and governance standards framework under Article 5. The framework is set out in Appendix VI; the reporting template is provided in Appendix VII.

5.1. Defining the reporting scope

For the legal compliance criteria in Section I of Appendix VI, the scope of reporting is defined as follows:

Report preparation requires coordination between the departments or people responsible for technical matters, the environment, human resources, finance and governance. The content should cover all three ESG groups within the scope described above.

5.2. Distinguishing legal compliance criteria from voluntary criteria

Legal compliance criteria in Section I of Appendix VI: businesses should identify the requirements applicable to their operations and provide corresponding information and evidence. Where a requirement does not apply, the reasons and supporting basis should be explained.

Voluntary criteria in Section II of Appendix VI: the selection must represent all three environmental, social and governance groups and meet the minimum number specified in Article 5(4):

Article 5(4) provides an exception for entities applying an environmental, social and governance standards framework based on international standards. When relying on this exception, the framework in use should be clearly identified and the relevant requirements reviewed. The exception should not be interpreted as an exemption from legal compliance or reporting obligations.

5.3. Organising report preparation and implementation

Businesses can organise the work through the following steps:

1. Define the entity, scope and data period: clarify the reporting scope and information collection period, and ensure consistency with the project explanatory report and relevant management records.
2. Compile the criteria list: review legal compliance requirements; determine enterprise size under the applicable rules; and select suitable voluntary criteria.
3. Collect evidence: record data sources, calculation methods, reference documents and responsible persons. Distinguish results already achieved from planned activities and targets.
4. Complete the report using Appendix VII: address all applicable content, check accuracy and consistency, and complete the reporting entity’s declaration of commitment.
5. Publish and implement: make the report publicly available on the entity’s website, if it has one; assign responsibility for implementing and monitoring the measures set out in the report.

The reporting entity is responsible for the information and data provided. Article 5 does not require every report to undergo independent verification. However, where a selected criterion requires independent audit or assessment, the entity must fulfil that requirement.

References: Article 5 and Appendices VI and VII to Decision No. 46/2026/QĐ-TTg.

6. Responsibilities after the determination document is issued

After the determination document is issued, businesses should designate a contact person to fulfil notification obligations, monitor conformity and maintain it in accordance with Article 6.

Management tip: Track the document issue date, notification deadline, submission date and evidence of receipt. Establish internal reporting arrangements for changes in technology, scale, raw materials or operations that may affect fulfilment of the criteria.

References: Article 6 and Appendices VIII and IX to Decision No. 46/2026/QĐ-TTg.

7. Pre-implementation self-review checklist

Businesses can use the checklist below to assess readiness and assign work. It is an internal management aid and does not replace the criteria and templates issued with the Decision.

For each item, record the completion status, outstanding work, responsible person and completion deadline.

8. Frequently asked questions