Mandatory GHG Inventories: Facility Responsibilities and Reporting

1. Legal framework and updates

• Law on Environmental Protection 72/2020/QH14, adopted on 17 November 2020 and effective from 1 January 2022.
• Decree 06/2022/NĐ-CP of 7 January 2022 on GHG mitigation and ozone-layer protection, as amended by Decree 119/2025/NĐ-CP, effective from 1 August 2025.
• Circular 01/2022/TT-BTNMT of 7 January 2022 and the relevant current sector guidance and amendments must be considered for the facility’s activities.
• The original article cited Decision 01/2022/QĐ-TTg. The updated facility list was issued under Decision 13/2024/QĐ-TTg, effective from 1 October 2024. Check the applicable list and subsequent updates for the reporting period.

2. Reporting timetable: distinguish the original milestones from current requirements

Mandatory duties apply to facilities within the prescribed list and scope. Other organisations may undertake voluntary inventories and mitigation, but voluntary participation does not automatically impose the same statutory deadlines.

• Historical milestone: submit the relevant 2022 activity data before 31 March 2023.
• The general biennial facility-inventory timetable starts with 2024 data, with reports sent to the provincial People’s Committee before 31 March from 2025. Apply the amended rules and the specific route for facilities allocated emission allowances.
• The former general instruction to finalise and send reports to the Ministry before 1 December 2025 must not be treated as a universal current deadline. Under the amended rules, allowance-allocated facilities submit verified inventory reports to the Ministry of Agriculture and Environment before 1 December from 2027, as applicable.

The original article described mitigation measures for 2023–2025. For implementation now, distinguish mitigation planning, annual mitigation reporting and obligations linked to emission allowances.

• Historical milestone in the original article: prepare the 2026–2030 mitigation plan before 31 December 2025 and update it as required. Use the applicable amended requirements and competent authority for the facility.
• Annual mitigation-result reports for the previous year are submitted to the relevant provincial People’s Committee before 31 March from 2027, under the applicable amended provisions.

3. Report and plan templates

• Facility GHG inventory: Form 06, Appendix II to Decree 06/2022/NĐ-CP, using the applicable amended version.
• GHG mitigation plan: Form 02, Appendix IV, subject to the applicable amended requirements.
• GHG mitigation-results report: Form 02, Appendix III, using the applicable amended version.

4. Administrative penalties: original legal reference

GHG mitigation violations and penalty provisions

The original article referred to Article 45 of Decree 45/2022/NĐ-CP, effective from 25 August 2022. The amounts below are the original individual-level fines; organisational fines are generally twice the corresponding individual fines. Check the applicable provision and amendments when assessing an actual case.

Types of violation described in the original Article 45

1. Warning for the following acts:

a) Failure to submit a required GHG inventory report to the competent authority.

b) Failure to submit a required emissions-reduction report to the competent authority.

2. Individual fine of VND 5,000,000–10,000,000 for the following acts:

a) Providing incorrect or incomplete information in a GHG inventory report.

b) Providing incorrect or incomplete information in an emissions-reduction report.

3. Individual fine of VND 30,000,000–50,000,000 for the following acts:

a) Failure to prepare a required GHG inventory report.

b) Failure to prepare a required emissions-reduction report.

c) Appraising a report outside the field announced by the competent Ministry, as described in the original provision.

5. When should a business start preparing?

Begin at the start of the reporting period, rather than waiting until the submission deadline. Organisations unfamiliar with the process should first clarify their reporting boundary, data responsibilities and applicable obligations.

ITVC Global supports GHG inventory projects through site review, activity-data collection, analysis, emissions calculations and uncertainty assessment, using ISO 14064-1 and applicable requirements. Verification or regulatory appraisal is a separate process and its outcome depends on the evidence and the competent reviewing body.

Early discussion helps the organisation determine where to start and establish reliable collection of operating information and data.

Even where a business understands the legal requirements, maintaining a consistent data process over six or twelve months can be challenging. Assign responsibilities and arrange suitable internal or external support early so that records are complete from the beginning.

References

Decision 13/2024/QĐ-TTg

Decree 119/2025/NĐ-CP

2025 consolidated text 10/VBHN-BNNMT

Decree 45/2022/NĐ-CP