Vietnam’s electricity market is no longer undergoing incremental reform—it is being fundamentally restructured.
This guide examines the legal and systemic transformation introduced by Circular 36/2025/TT-BCT, an instrument that, while formally framed as an amendment to the competitive wholesale electricity market, in substance redefines the underlying logic through which the market operates. Rather than refining existing mechanisms, the reform reorders the hierarchy of dispatch, integrates contractual and policy constraints into system architecture, and recalibrates the allocation of risk across the power value chain.
At its core, the reform marks a departure from a model centered on economic merit-order dispatch toward a policy-integrated framework, where legal obligations, fuel strategies, and system reliability considerations are embedded directly into operational and financial outcomes. Concepts traditionally confined to contractual or financial domains—most notably “bao tiêu”—are reconstituted as determinants of dispatch, while curtailment evolves from a technical outcome into a regulated mechanism of risk allocation.
It is structured to provide a comprehensive and layered analysis of this transformation. It further examines the doctrinal shifts underpinning the reform, the operational reconfiguration of dispatch and curtailment, the integration of constraints into market modelling and settlement, and the resulting implications for project structuring, financing, and investment strategy.
The objective is not merely to describe regulatory changes, but to interpret their systemic consequences. For market participants—developers, investors, lenders, and policymakers alike—the significance of Circular 36 lies in its redefinition of how value, risk, and priority are determined within Vietnam’s power sector.
Understanding this shift is essential. The market continues to function, but no longer on the basis of price alone. It is now structured by design.