On 17th September 2026, the Prime Minister issued Decision No. 46/2026/QD-TTg providing guidance on the identification of “green projects“, projects meeting circularity criteria, and the application of the Environmental, Social and Governance (ESG) framework. The Decision takes effect from 1st November 2026. This provides a specific legal basis for identifying green projects and projects meeting circularity criteria, standardising ESG application, and serving as a basis for considering support mechanisms, including interest-rate support for the private sector.
- Subjects of the Decision
The Decision applies broadly to stakeholders in the green finance ecosystem, including:
- Private-sector enterprises, household businesses and individual business owners, particularly those investing in or planning to seek identification of green projects, projects meeting circularity criteria, and application of the ESG framework.
- Independent assessment organisations responsible for assessing projects and issuing project identification documents.
- Authorities responsible for implementing interest-rate support policies, commercial banks and state financial funds.
Therefore, not every enterprise is required to comply with all of the requirements under the Decision. However, understanding the regulations early can help businesses prepare more proactively when working with banks and financial institutions.
- Conditions for a project to be identified as “green”
Under Clause 1, Article 3 of the Decision, a green project must simultaneously satisfy three conditions:
- Fall within one of the project types listed in Appendix I, covering seven sectors: energy; transport; construction; water resources; agriculture, forestry and fisheries; processing and manufacturing; and environmental services;
- Have an appropriate environmental objective;
- Meet the specific technical requirements applicable to that project type. The use of renewable energy, water-saving measures or recycling does not automatically qualify a project as a green project – the project must be assessed against the relevant requirements in Appendix I.
For example, a wind power project must meet the following requirements:
| Project type | Objective | Requirements |
| Wind power generation | Climate change response | The following requirements must be met simultaneously: 1. Wind power generation must be from one of the following types: 1.1. Offshore wind power; 1.2. Onshore wind power. 2. Equipment used for wind power generation must be certified for conformity, inspected and calibrated in accordance with applicable laws and regulations. |
Source: Appendix I to Decision No. 46/2026/QD-TTg dated 17th September 2026 of the Prime Minister.
In parallel, the Decision identifies four groups of projects meeting circularity criteria: circular design and production; circular use; resource recovery; and industrial symbiosis/circular linkages. These projects must meet the corresponding requirements in Appendix II.
- Who is authorised to identify green projects? What documents are required?
Under Article 4 of the Decision, project identification is conducted through an independent assessment organisation that satisfies requirements regarding legal status, scope of activities and professional capacity, including requirements related to ISO/IEC 17029, ISAE 3000 or equivalent standards.
For green projects, the application dossier includes a request form under Appendix III and an explanatory report under Appendix IV. For projects meeting circularity criteria, Appendix III and Appendix V apply. The templates were issued together with the Decision. Businesses therefore need to prepare specific data and supporting evidence for each applicable criterion, rather than relying solely on qualitative commitments.
- Benefits for businesses
A notable financial benefit is the possibility of being considered for interest-rate support of 2.0% per year when borrowing to implement green or circular projects and apply the ESG framework, pursuant to Clause 1, Article 9 of Resolution No. 198/2025/QH15. Decision No. 46/2026/QD-TTg provides a basis for identifying eligible projects and demonstrating ESG implementation as part of the consideration process for such support.However, being identified as a green or circular project does not automatically entitle a business to interest-rate support. Businesses must still satisfy the applicable conditions of the relevant credit support policy. Beyond financial benefits, a standardised set of documentation and data can also help businesses improve transparency when working with banks, investors, customers and supply-chain partners.
- ESG requirements accompanying green projects
Article 5 of the Decision specifies that ESG reporting requirements apply to enterprises, household businesses and individual business owners implementing green projects or projects meeting circularity criteria. In addition to complying with legal requirements relating to environmental, social and governance matters, applicable entities must select a minimum number of voluntary ESG criteria according to their size. Unless an international ESG framework is applied, the selected criteria must represent all three pillars – Environmental, Social and Governance:
- Household businesses/individual business owners: 3 criteria
- Micro and small enterprises: 6 criteria
- Medium-sized enterprises: 12 criteria
- Other enterprises: 18 criteria
This requires cross-functional coordination among ESG, legal, finance, human resources, production and other relevant departments.
- Obligations after a project has been identified
Under Article 6 of the Decision, enterprises, household businesses and individual business owners implementing projects that have been identified as green projects or projects meeting circularity criteria have several key responsibilities:
- Within 30 days from the date the identification document is issued, submit written notification of the identification result to the provincial-level People’s Committee where the project is implemented, using the form in Appendix VII.
- Publish the ESG report on the enterprise’s website, if any.
- Within five working days, notify the provincial-level People’s Committee and the independent assessment organisation if changes cause the project to no longer meet the applicable criteria or if the project is discontinued, using the form in Appendix IX.
- What should businesses with green projects do now?
- Compare their projects against Appendix I/II to identify the correct project category.
- Review environmental legal documentation, including EIA documents, environmental permits, monitoring records and waste management records.
- Standardise operational data on electricity, fuel, water, raw materials and greenhouse gas emissions.
- Review and select the required number of voluntary ESG criteria based on enterprise size.
- Establish a document and evidence management system covering permits, certificates, data and reports so the project is ready for independent assessment.
Decision No. 46/2026/QD-TTg moves the concept of a “green project” from a broad policy direction toward a system of criteria that can be measured, evidenced and verified. Businesses seeking identification of a green project or a project meeting circularity criteria should therefore determine the applicable criteria early, conduct a gap assessment, standardise environmental, greenhouse gas and ESG data, and build an evidence system to support independent assessment.
Contact ESGreen for support in reviewing applicable criteria and preparing green project documentation:
Phone: 0856 357 968
Email: contact@esgreen.vn
Address: 8th Floor, Diamond Flower Building, 48 Le Van Luong Street, Yen Hoa Ward, Hanoi, Vietnam
Website: https://esgreen.vn/