Resolution No. 198/2025/QH15 entitles enterprises, household businesses and individual business operators to interest rate support of 2% per annum when borrowing to implement green or circular projects and applying an ESG framework. However, the Resolution does not define what constitutes a green project; as a result, such labelling has largely relied on self-declaration by project owners.

Decision No. 46/2026/QD-TTg, signed on 17 September 2026 and effective from 1 November 2026, changes this through three layers of conditions: the project meets the technical criteria, is determined by an independent assessment organisation, and its owner applies an ESG framework.

1. Criteria for green projects and circular projects

Appendix I lists 45 types of green projects across 7 sectors: energy, transport, construction, water resources, agriculture, forestry and fisheries, manufacturing, and environmental services. Each project type is accompanied by specific technical requirements; for example, new water supply systems must have a water loss rate not exceeding 15%, and construction works must hold green building certification.

Circular projects (Appendix II) fall into four groups: circular design and production, circular use, resource recovery, and industrial symbiosis.

2. Determination by independent assessment organisations

Under Article 4, only an independent assessment organisation may determine that a project is a green project or a circular project. Such an organisation must simultaneously satisfy four conditions:

• Having legal entity status;
• Being registered for business in Vietnam or established under a decision of a competent state authority;
• Providing conformity assessment services or audit services;
• Meeting TCVN ISO/IEC 17029:2020 (or ISO/IEC 17029:2019), or performing engagements in accordance with assurance standards VSAE 3000/ISAE 3000.

The project owner submits a written request and a project explanatory report using the prescribed templates. The timeline and fees are agreed between the two parties. The assessment organisation is responsible before the law for the determination results.

3. ESG framework as an accompanying condition

Under Article 5, the project owner must satisfy all legal compliance criteria and additionally select a minimum number of voluntary ESG criteria depending on its size:

Enterprises already applying an ESG framework in accordance with international standards are not bound by these thresholds. The ESG application report serves as the basis for considering interest rate support.

4. Obligations after determination

• Within 30 days from receipt of the determination document: notify the provincial People’s Committee where the project is implemented;
• Within 05 working days from ceasing the project or no longer meeting the criteria: report to the provincial People’s Committee.

Provincial People’s Committees publish the list of green and circular projects on 30 June and 31 December each year.

5. What enterprises need to do

1. Review early. The Decision contains no transitional provisions. Projects with existing or planned loans should be checked against Appendices I and II now.
2. Prepare evidence. The project explanatory report requires technical data and certifications (conformity certification, energy labels, eco-labels).
3. Build the ESG framework in parallel. Meeting 6 to 18 voluntary criteria requires actual policies and data, which cannot be completed within a few weeks.