On 4 July 2025 the Decision No. 21/2025/QĐ-TTg (Decision 21), Regulation on Environmental Criteria and Verification of Investment Projects under the Green Taxonomy, was issued establishing the official framework for classifying investment projects as “green.” Effective from 22 August 2025, this new regulation provides the legal framework for the development of a green finance market – for environmentally sustainable projects.

Decision 21 is a key measure in operationalizing Vietnam’s national strategy on green growth and climate change mitigation. Below are some key points:

1. Environmental criteria for green-classified investment projects

To qualify for “green classification”, a project must comply with applicable environmental licensing procedures (e.g., environmental impact assessment approval, environmental license, or environmental registration, unless exempted) and demonstrate a positive environmental contribution.

45 eligible sectors are listed in Decision 21 which fall within 7 overarching industry groups:

• renewable energy – solar, wind, biomass, small hydro and other clean energy technologies
• clean transportation – electric vehicles, public transit systems and infrastructure supporting low-emission mobility
• green buildings and urban development
• agriculture and forestry – organic farming, agroforestry, sustainable land use and biodiversity conservation
• water and wastewater management – water conservation, wastewater treatment and water infrastructure
• energy efficiency
• pollution prevention and control  

2. Verification of green status

Verification can be upon the request of a project developer which will allow for greater access to green capital and transparency and credibility of lenders.

Verification of a project’s green classification may be issued either by:

• The competent State agency responsible for environmental licensing (e.g., the Ministry of Natural Resources and Environment or the relevant provincial People’s Committee, depending on the scale and nature of the project); or
• An independent verification organization registered in Vietnam with expertise in conformity assessment or audit services and adherence to national/international assurance standards.

The application dossier requirements vary depending on the confirming entity:

• When applying via a State agency: the green classification request must be integrated into the existing environmental approval application, with an explanation of how the project meets sector-specific green criteria; and
• When applying via an independent organization: the application must include a written request, approved environmental documentation, and a justification report submitted at the time of seeking green credit, green bonds, or incentives.

3. Post-verification obligations

Within 30 days of receiving verification of green status, the project owner must notify the Ministry of Natural Resources and Environment for national-level tracking.

Decision 21 is a pivotal step toward aligning Vietnam’s regulatory landscape with global green finance trends. By introducing clear criteria and verification pathways, the framework increases transparency and legal certainty for investors and financial institutions in accessing the green finance market. It is expected to catalyse greater capital flows into sustainable sectors and reinforce Vietnam’s climate and development commitments.

Project owners seeking green classification should begin preparing relevant documentation and monitor further regulatory developments ahead of the effective date later this month.

For more information or assistance in assessing your project’s eligibility under Decision 21, please contact the DFDL Vietnam team.

The information provided here is for information purposes only and is not intended to constitute legal advice. Legal advice should be obtained from qualified legal counsel for all specific situations.

Key Contacts

Phong Anh Hoang, Partner

Kristy Newby, Partner, Co-Head of Regional Energy, Natural Resources and Infrastructure Practice I Co-Head of Regional Compliance and Investigations Practice