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Vietnam’s Enhanced Energy Efficiency Framework and Investment Outlook

Written by Senior Foreign Counsel Vaibhav Saxena

On 21 January 2026, the Government issued Decree No. 30/2026/NĐ-CP (“Decree 30”), with effect[1] and replacing Decree No. 21/2011/NĐ-CP and detailing implementation of the Law on Economical and Efficient Use of Energy (as amended in 2025).

Decree 30 materially strengthens Vietnam’s energy efficiency governance framework by:

  • Formalizing compliance obligations for key energy-consuming facilities;
  • Centralizing and professionalizing the regulation of energy audit organizations;
  • Tightening the energy labeling and market surveillance regime;
  • Establishing the legal framework for a Fund for Promoting Energy Saving and Efficiency;
  • Linking qualifying projects to potential inclusion in the list of green investment projects.

Key Energy-Consuming Facilities: Expanded Compliance Exposure

Thresholds

A facility qualifies as a “key energy-consuming facility” if annual energy consumption equals:

  • ≥ 1,000 TOE – industrial, agricultural production facilities and transportation units;
  • ≥ 500 TOE – buildings (offices, hospitals, schools, hotels, commercial centers, etc.).

Energy calculation includes electricity, coal, oil, gas and other forms of energy consumed at the operating location.

For transportation businesses operating at multiple addresses, each branch location is assessed separately.

Annual Provincial Listing

Provincial People’s Committees must issue the list of key facilities annually before 31 March and submit it to the Ministry of Industry and Trade MoIT.

Mandatory Planning

Key facilities must prepare:

  • Annual energy saving and efficiency plans; and
  • Five-year plans.

Plans must assess prior implementation results and establish reduction targets and monitoring mechanisms.

Business implication:
Large industrial groups, logistics operators and commercial real estate owners should conduct immediate TOE reassessments and align internal energy governance with five-year planning cycles to mitigate inspection risk.

Energy Audit Organizations: Professionalization and Central Oversight

Core Requirements

Energy audit organizations must:

  • Be legally established;
  • Employ at least three certified energy auditors (≥12-month contracts);
  • Appoint a technical manager (≥5 years’ experience + certificate);
  • Appoint a QA/QC officer (≥3 years’ experience + certificate);
  • Maintain calibrated measurement equipment and management procedures;
  • Conduct annual auditor training.

Publication and Reporting

  • MoIT must review and publish qualified organizations within 10 working days of a complete application.
  • Annual reporting is required before 31 January.
  • Changes to qualifying conditions must be notified within 10 days.

Energy Labeling: Tightened Compliance and Market Surveillance

The Decree strengthens the regulatory framework for energy labeling of vehicles, equipment and construction materials.

Label Categories

  • Comparative labels
  • Certification labels
  • Vehicle energy labels

Energy efficiency indices derive from national standards issued by competent authorities.

Declaration Requirements

Manufacturers and importers must submit:

  • Technical specifications;
  • Testing results from officially published laboratories;
  • Label declaration;
  • Proposed label design.

Suspension and Revocation

Labeling may be suspended or revoked for:

  • Counterfeit or undeclared labeling;
  • Incorrect energy performance data;
  • Fraudulent documentation;
  • Repeated violations.

Provincial authorities are expressly empowered to inspect products circulating in the market, including on e-commerce platforms.

Reporting Deadlines

  • Statistics on labeled products: before 1 March annually;
  • Manufacturer/importer reports to PPC: annually;
  • PPC compilation to MoIT/Ministry of Construction: before 31 March.

Phase-Out Mechanism for Inefficient Equipment

Vehicles and equipment may be subject to mandatory phase-out where:

  • Safety standards are not met;
  • Energy efficiency falls below the minimum level set by the Ministry of Science and Technology;
  • Policy considerations require removal.

The Prime Minister will promulgate the official phase-out list.

National Program and Financial Support Architecture

National Program on Energy Saving and Efficiency

The Prime Minister approves and oversees the National Program.
MoIT locates as Standing Committee.

Program components include:

  • Institutional reform and standard development;
  • Technology deployment;
  • Public awareness;
  • Project support.

Green Investment Classification

Projects involving:

  • Energy-efficient technology upgrades reducing GHG emissions;
  • Conversion to energy-saving product manufacturing;
  • Digital transformation in agriculture promoting energy efficiency;

may be considered for inclusion in the list of investment projects classified as green.

Fund for Promoting Energy Saving and Efficiency

The Decree establishes the legal framework for a dedicated Fund financed through:

  • State budget charter capital;
  • Domestic and foreign grants and contributions;
  • Retained operating capital;
  • Borrowed capital (subject to repayment capacity).

Note: The Decree creates a structured financing ecosystem that may support blended finance, concessional lending and ESCO models. Investors should monitor forthcoming decisions on Fund establishment and operational guidelines.

Inspection and Enforcement Framework

  • Energy plans and audits of key facilities;
  • Activities of energy audit organizations;
  • Energy labeling compliance;
  • State-funded agency compliance;
  • Prohibited acts (such as, destruction of energy resources, fraud or abuse in obtaining energy efficiency incentives, misrepresentation of energy performance, and the production, import, or circulation of phased-out energy-consuming vehicles and equipment).

Remarks

Decree 30 represents a regulatory consolidation rather than a radical policy shift. However, it materially increases procedural rigor, reporting discipline and inspection authority across:

  • Large industrial and transport operators;
  • Commercial real estate assets;
  • Manufacturers and importers of energy-consuming products;
  • Energy audit providers;
  • ESCOs and efficiency investors.

At the same time, it establishes a clearer policy and financing platform for energy efficiency investment aligned with Vietnam’s green growth and emissions reduction trajectory.

[1] Existing energy management certificates remain valid until 31 December 2030.