OECD-ENV Vietnam questionnaire key points

1
CEFIM Viet Nam Questionnaire
Key Points

I.a. Long-term goal setting to promote clean energy
investments
• Viet Nam has set a number of energy sector related GHG
mitigation targets in high level strategies including: • In 2020 Viet Nam became only the 9th country to submit a
revised NDC. Mitigation targets were marginally revised up
from 8 to 9% unconditional and from 25 to 27% conditional
compared to BAU at 2014 base year. The NDC places a heavy
focus on the energy sector for mitigation potential as below:

investments
• In 2015 government of Vietnam (GoV) adopted the National
Renewable Energy Development Strategy 2016-2030 with
outlook to 2050 (NREDS). The Strategy guides RE development
in the country setting medium and long-term goals.
• NREDS targets RE generation to cover 7% of total in 2020 and
10% by 2030 (from less than 1%, excluding hydro, in 2014).
• Power development plans (PDPs) set medium-term targets for
new capacity additions. In 2016 the GoV revised PDP VII 2011-
2016 with a vision to 2030 (Decision No. 428/QDTTg) with the
aim to “accelerate the expansion of renewable power sources
(hydro, wind, solar, biomass power, etc”
• The revised technology deployment targets reflect this:
• The revised PDP VII sets specific technology capacity targets
(MW) and generation mix targets (%) for wind, solar, and
biomass power as below:
2020 2025 2030

investments
0.47 0.80 2.00 6.00
20.44 21.60
24.60
27.80
5.74 0.85
4.00
12.00
0
5
10
15
20
25
30
35
40
45
50
2020 2020 2025 2030
RE Installed Capacity PDP 7 Revised Capacity Target
GW
Hydropower, Solar, & Wind Installed Capacity 2020 Vs. Power Development Plan VII Revised Targets
Wind (GW) Hydro (GW) Solar (GW)
Note: The PDP VII revised does not specify capacity targets for biomass power projects instead setting the target of 2.1% of total electricity generation by 2030
Source: GoV(2016), Prime Minister’s Decision No. 428/QD-TTg approving the revised PDP VII
EVN National Load Dispatch Centre.

investments
Wind Thermal Power - Oil
Solar
Import
Small Hydro
Gas turbine Thermal Power - Coal
Biomass
Large hydro
Structure of Vietnam electricity generation capacity
Nov 2020
Total Capacity
56,162 MW
466 MW
5,739 MW
1,274 MW
4,144 MW
4,144 MW 19,696 MW
16,293 MW
162 MW
1,449 MW
Structure of Vietnam electricity generation capacity
Nov 2020 (source: EVN NLDC)
Selected regional grid capacity vs approved pipeline Dec2020

investments
• PDP VIII 2021 – 2030 with a vision up to 2045 is expected for
prime minister approval early 2021.
• Prime Minister's Decision No. 1264 set principles for the design
of the PDPVIII including:
• The prioritization of appropriate development of power
sources utilizing renewable energy
• The economic and efficient use of power
• PDPVIII design progressed during the transition period for a
newly revised planning law. This was a source of delay as no
detailed guidelines were published confirming the official
process of approving pipeline projects for inclusion
• The revised planning law centralises the planning process by
removing approval authority from provincial governments and
instead requiring all projects to be approved by MOIT and the
PM for inclusion in the national plan
• Resolution No. 21 was published Jan 2020 clarifying PDP
project approval process – it sets the order of priority for
inclusion in the plan by energy sources, generation technologies
and characteristics of projects such as location, grid connection
plan, development progress and scale, among other factors.
• Circular No. 43/2013/TT-BCT dated December 31, 2013 of
MOIT entitled regulations on content, sequence, procedures for
Viet Nam’s Politburo passed Resolution 55 in Feb 2020 setting
the orientation for the National Energy Development Strategy
to 2030 with outlook to 2045. It sets forth a clear focus to scale-
up renewable energy and accelerate market focused reforms
(selection of priorities included below):
•Build a synchronous, competitive and transparent energy
market with diverse forms of ownership and business models;
•Emphasize the integrated and reasonable development of
diversified types of energy sources;
•Prioritize the thorough and efficient exploitation and use of
renewable, new and clean energy sources;
•Build a roadmap for the reasonable reduction of the power
share of coal-fired power projects;
•Accelerate digital transformation in the energy sector.

investments
MOIT’s Institute of Energy leads the modelling that
underpins the PDPVIII design – a July consultation
workshop presented initial scenarios that include:
• Wind power capacity is 3 times higher and solar power
is ~ 2 times higher than that in PDP7 revised (PDP7A).
• No new coal power plants in the period of 2026-2030.
• More than 17GW of imported coal power approved in
the PDP7A will be delayed to the period after 2030 or
cancelled.
• As RE development concentrated in the South, there
will be high demand of transmission to the North
From 2025, especially transmission from Central South
to North.
• After 2025, flexible sources are essential for the power
system to ensure supply and back up for wind and solar
power. There is a necessity to have policy on back up
capacity tariff

investments
The Viet Nam Energy Efficiency Program III (2019-
2025 with orientation to 2030) sets economy wide and
sectoral energy reduction targets compared to BAU.
(presented to the right). Over the past 10 years, Viet
Nam has achieved energy efficiency reductions of 3.4%
during 2006-2010 and 5.65% during 2011- 2015 during
the VNEEP II implementation period.
Energy efficiency targets were also introduced by
Resolution 55-NQ-TW of Politburo in Feb 2020 which
was aimed at orienting the upcoming national energy
master plan.
+ The energy-saving over the total final energy
consumption against business as-usual (BAU) scenario
to reach 7% by 2030 and up to 20% by 2045.
N. Goal
Goal by 2025
Goal by 2030
(orientation)
National National
1
Energy savings of total commercial
energy consumption (compared to
BAU)
5,00 -7,00% 8,00 -10,00%
2
Energy savings in industry
compared to 2015 - 2018
- Steel 3,00 -10,00 % 5,00 – 16,50%
- Chemical products 7,00 % 10,00%
- Plastic 18,00 – 22,46 % 21,55 – 24,81%
- Cement 7,50 % 10,89%
- Textile 5,00 % 6,80%
- Alcohol, Beer, Soft Drink 3,00 – 6,88 % 4,6 – 8,44%
- Paper 8,00 – 15,80 % 9,90 – 18,48%
3
petroleum consumption in
transport sector
5%

I.b. Mapping of renewable energy resources
• The World Bank project with MOIT “Renewable Energy Resource Mapping and Geospatial
Planning – Vietnam” was implemented in three phases from 2015 to 2018 with the aim to improve
renewable energy resource mapping in Viet Nam.
Solar and wind maps for Viet Nam were produced and publicly available on the Global Solar
Atlas and the Global Wind Atlas.
Resource maps for biomass and small hydro potential also developed and publicly available
• World Bank ESMAP-IFC Offshore Wind Development Program launched in March 2019 and has
provided technical potential estimation for offshore wind within 200km of shoreline – maps and
data publicly available
• The Vietnam Meteorological Hydrological Administration under the Ministry of Natural
Resources and Environment (MONRE) operates a network of 181 surface synoptic stations and 354
hydrological stations
• National Land Information System (NLIS) initiative led by MONRE includes a national land
database, a national land information portal and a unified electronic land registration system
throughout the country. The NLIS, as part of an overall e-government agenda, seeks to improve
access to land use data for socio economic planning and for enterprises

I.b. Mapping of renewable energy resources
166
217
309
7
35
3.42
0.13 0.03
5.28
51.63
0
10
20
30
40
50
60
-
50
100
150
200
250
300
350
Solar Wind Onshore Wind Offshore Bioenergy Hydro
Utilisation
rate
(%)
Potential
capacity
(GW)
Potential Capacity (GW) Utilization Rate (%)
a)

I.c. Energy efficiency evaluation and demand forecasting
• The institute of energy is responsible for system modelling which
uses energy demand growth forecasts as a key input. BAU, low and
high demand growths are estimated factoring energy saving of 1.5 -
2% in 2021-2030, 4% by 2050. PDP VIII model scenarios do not
factor in more ambitious demand side targets. It is not clear
whether the cost optimisation model outputs consider cost effective
demand side measures equally with additional generation sources.
•
• The graph to the right shows the historic energy demand growth
trend against modelled estimates from PDP IV onwards. To date
demand forecasting has matched actual trends.
• Designated enterprises under the Efficiency Law are required to
submit 5 year plans to local offices of MOIT, MOT, or MOC
(depending on sector). The 5 year plans outline the results of a
compulsory energy audit and the energy savings potential. MOIT
are responsible for setting up database to collate the data source for
use in planning and monitoring.
0
200
400
600
800
2010 2015 2020 2025 2030 2035
TWh
Historical data PDP 4 (1995) - Low scenario
PDP 4 (1995) - Base scenario PDP 4 (1995) - High scenario
PDP 5 (2001) - Base scenario PDP 5 (2001) - High scenario
PDP 6 (2007) - Low scenario PDP 6 (2007) - Base scenario
PDP 6 (2007) - High scenario PDP 7 (2011)
PDP 7R (2016) Linear (Historical data)
Actual energy demand trend vs PDP forecasts
USAID’s Vietnam Clean Energy Program, provided local authorities technical
support and training to improve data management, collection and analysis
capability in construction, encompassing power usage in office buildings,
hospitals, hotels, apartment buildings, schools and commercial buildings

I.d. Policy coherence, co-ordination and monitoring
• The Ministry of Planning and Investment (MPI) performs functions of state management over planning (among others)
including advice on strategies, master plans, plans for national socio-economic development and public investment
• The overarching strategy for economic and social development comprises the 10-year Social Economic Development Strategy
(SEDS) and the five year Socio-Economic Development Plan (SEDP). The actions needed to translate the 10-year SEDS into
reality are described in the five-year SEDPs. Each SEDP provides a framework for different ministries for their own sector
plans to promote policy coherence.
• The orientation of sectoral planning is set by resolutions issued by the Prime Minister (who has overall responsibility for
ministry activities) or by the Politburo (the highest body of the Communist Party of Vietnam)
• MOIT has overall responsibility for the energy sector master plan and the national power development plan. MOITs regional
departments DOIT work with provincial authorities on coordinating regional planning
• All sectoral plans are submitted to the Prime Minister for approval
• All policy and target reports are monitored and evaluated by the Prime Minister’s office

I.e. Electricity market governance
• Vietnam’s Electricity Law (2004) sets out the framework for the introduction of a competitive power market, restructuring
of the public utility, Vietnam Electricity (EVN) and its various units and subsidiaries, and the establishment of a regulatory
unit within MOIT– Electricity Regulatory Authority of Vietnam (ERAV). ERAV’s responsibilities include: setting grid codes
and standards; issuing licenses and monitoring compliance; reviewing power sector plans and financing needs; advising on
tariffs; and preparing and enforcing regulations for competitive power markets
• ERAV’s budget composition is unclear and the majority of ERAV’s funding appears to not come from levies, which implies a
structural dependence on government. Legal appeals are formally allowed. In practice, however, lack of transparency
around recommendations, and lack of broad formal participation in decisions, reduces the likelihood that a wide set of
stakeholders would be positioned to meaningfully engage in the regulatory process (World Bank Policy Research Working
Paper 9169)
• ERAV does not monitor compliance with the terms of licenses, and has no authority to impose penalties for violation of
license or permit terms, or other contractual provisions. However, companies have been forced to relinquish licenses for a
violation of license terms or contracts. Over 10 licenses were withdrawn in 2014 and 2015 due to not meeting requirements
such as metering requirements or not complying with requirements to notify ERAV of relevant changes. (World Bank Policy
Research Working Paper 9169)

II.a. Energy efficiency policies and regulation
• The Electricity Law issued in 2004 gives the overall legal basis for the promotion of energy efficiency. It placed an obligation on MOIT to
draw up energy efficiency action plans, to develop efficiency standards, to introduce fiscal incentives, and undertake awareness raising.
• the Viet Nam Energy Efficiency Program (VNEEP I & 2) was approved in 2006 by Decision No. 79/2006/QD-TTg with phase I covering
2006-2010 and phase II covering 2011-2015. As well as setting economy wide targets (3-5% and 5-8% reduction against BAU respectively)
it required a number of regulatory activities over the implementation period: Developing the legal framework for EE, including the EE Law
and building codes; ▪ Developing energy management (EMS) for industries and buildings; ▪ Developing energy pricing policies and
regulations to promote EE; ▪ Introducing Minimum Energy Performance Standards (MEPS) and EE labelling; and ▪ strengthening the EE
technical network, with eight energy conservation centres.
• At the same time in 2006 decision 80/2006/QDTTg approved the 2006-2010 Electricity Saving Program which required the development
of energy efficiency awareness programs on radio and TV and also set requirements for 10% reduction in energy costs from public buildings
through lighting upgrades
• During the VNEEP I & II implementation period a number of important policy and regulatory actions were achieved:
• Law No. 50/2010/QH-12 on Economical and Efficient Use of Energy requires ‘designated-energy users’ to appoint a qualified energy
manager, to undertake energy audits every 3 years, and to formulate annual and 5 yearly energy reduction plans. Decree No.
21/2011/ND-CP on implementation of law 50 was then adopted and defined major energy users as industry and agri businesses with total
energy consumption over 1,000 TOE per year and any non-industrial (both residential, commercial, hospitals and education) buildings
with over 500 TOE or higher
• Decree 134/2013/ND-CP gave a number of state actors authority to impose warnings and financial sanctions for breach of Law 50.

VNEEP I & II implementation (continued):
• Decision 1221/2018/QD-TTg approved by MOIT published the list of designated energy users that are required to comply with Law 50.
MoIT has issued energy efficiency circulars for six energy intensive industries which regulate minimum energy performance standards
including chemical, iron and steel, pulp and paper, plastic, beverage and seafood processing. Those industries are mandated to achieve
minimum energy performance set by MoIT’s circulars, the circulars also recommend technical best practice for achievement of targets.
MOIT Circular 02/2014/TT-BCT on Solutions for Economical and Efficient Use of Energy on Industries; Energy Consumption Quota in the
Chemical Industry
During VNEEP II 77 industrial plants announced an energy management plan (EMP), 15 companies have received certifications for ISO
50001—a global standard for energy management developed by the International Organization for Standardization in 2011—and 5 case
studies have been presented in the EE network. In total, 65 companies have completed assessment of steam systems, of which 62 invested in
steam system improvement; and 85 companies completed assessment of air compression systems, of which 77 invested in system
improvement. (2017 RCEE NIRA evaluation of VNEEP Phase II -Danida)

Over VNEEP II implementation period the energy intensity of key industry sectors improved by as much as 20% or more :
Energy intensity improvement in key industrial sectors over VNEEP II implementation period

Voluntary energy labelling was introduced in Circular No. 08/2006/TT-BCN intended as a transition phase to establish labeling procedures, design of
the labels, and the technical standards underpinning labelling performance tiers. Technical standards underpinning labelling tiers were introduced for 5
equipment classes: group 1 - lighting, residential appliances, and air conditioners, Group 2 – commercial & office appliances. Group 3 - Industrial three
phase motors, transformers, and chillers Group 4 – Cars with less than 7 seats. Group 5 – Solar water heaters and public lighting.
A mix of endorsement labels and comparative labels were introduced depending on the technology type
During this time EE testing facilities were set up QUATEST1, 2 & 3, and marketing campaigns undertaken to increase awareness of labels
Decision 51/2011/QĐ-TTg introduced the shift to mandatory labeling for some appliances, introduction of MEPS and a roadmap for implementation
Decision 68/2011/QĐ-TTg placed a requirement on all public agencies to procure only those appliances which met the 5 star or endorsement label
requirements
Significant progress was also made during the VNEEP I&II period in implementing appliance labelling and Minimum Energy Performance
Standards (MEPS) as prioritized in the 2004 Energy Law.
Equipment type Mandatory labelling Implemented MEPS introduced
household appliances and lighting January 1, 2013 Incandescent bulbs over 60W banned Jan 1 2013
Household appliances Jan 1 2014
Industrial equipment January 1, 2013 January 1, 2015
Commercial & office equipment January 1, 2014 (only commercial
refrigerators)
January 1, 2015
Transport January 1, 2015 none

By March 2014, over 4000 products had been registered in compliance with the mandatory labelling and MEPS programmes. An analysis of
the products registered in compliance with the mandatory 1-5 star labelling regulations by March 2014 showed the following distribution of
energy efficiency performance:
In 2019 CLASP undertook an evaluation of the air conditioner (AC)
market. The MEPS for ACs were previously revised in 2015, but due
to the rapid market transformation towards more efficient
technologies the analysis found that performance had outpaced both
the MEPS and the energy label ratings. The high proportion (76%) of
4-5 star models on the market indicates that Vietnam should rescale
the star rating system for ACs and revise the MEPS. The efficiencies
of most ACs found on the market are far above the current 2015
MEPS, indicating that the market is ready for more stringent MEPS
https://energy-evaluation.org/wp-content/uploads/2019/06/2014-berlin-charles-michaelis.pdf

Under VNEEP in September 2013, the Ministry of Construction adopted the National
Energy Efficiency Building Code QCVN 09:2013/ BXD (VEEBC), which set mandatory
technical standards for the design, construction or retrofit of civil buildings (office
buildings, hotels, hospitals, schools, commercial buildings, services buildings, apartments
buildings, among others), with a gross floor area of 2,500 m2 or larger. VEEBC was
updated in 2017
VNEEP III (2019-2030) sets a specific goal to verify that 100% newly built or repaired
building/construction applies the 2017 building standard
There is no mandatory certification scheme for buildings in Viet Nam but a number of
voluntary schemes coexist:
There were 86 LEED certified buildings in Viet Nam by end of 2017 with the first Gold
standard LEED certification issued to an office building in 2012
The LOTUS Certification system for buildings was developed in 2010 specifically for the
Vietnamese context by the Vietnam Green Building Council (VGBC), covering most of the
nonresidential and residential building types
IFC launched its own building certification scheme ‘EDGE’ in 2015
10 non residential buildings also hold Singapore’s Building Construction Association Green
Mark certification
2018-09-ee-in-buildings-vietnam-1.pdf (unepdtu.org)

PERIOD UP
TO 2025
PERIOD UP TO
2030
NATIONAL ENERGY REDUCTION
TARGET (COMPARED TO BAU)
5 - 7% 8 – 10%
TOTAL POWER SYSTEM LOSSES 6.5% 6.0%
STEEL INDUSTRY 3 - 10% 5 – 16.5%
CHEMICAL INDUSTRY Minimum 7% Minimum 10%
PLASTIC MANUFACTURING
INDUSTRY
18 - 22.46% 21.55 - 24.81%
CEMENT INDUSTRY Minimum
7.5%
Minimum
10.89%
TEXTILE & GARMENT INDUSTRY Minimum 5% Minimum 6.8%
BEVERAGE INDUSTRY 3 – 6.88% 4.6– 8.44%
PAPER INDUSTRY 8 – 15.8% 9.9 – 18.48%
Sub-sectoral targets represent a reduction in average energy consumption
compared to 2015-2018 period, level of achievement dependent on product type
PM Decision No.: 280/QD-TTg in 2019 approved the
VNEEP III for the period 2019-2030
VNEEP III sets overall targets and sub-sectoral targets as set
out in the table to the right. A selection of specific targets are
also described below:
•To achieve 90% of industrial parks and 70% of industrial
clusters applying efficiency solutions
•To implement energy labeling for 50% of all kinds of
building materials that require thermal insulation used in
construction works;
• To achieve 100% of centrally-affiliated cities and provinces
developing and approving plans/Programmes on economical
and efficient use of energy a the local level;
• To achieve 150 constructions certified “green works”
• To give training and issue certificates to 5,000 energy
management/energy audit specialists;
• To achieve 100% of schools conducting dissemination and
education on economical and efficient use of energy;
The VNEEP III also calls for the implementation of
important policy and regulation including ESCO regulations
and the proposal for the establishment of an energy
efficiency fund.

II.b. ESCO regulation & market development
There are more than 220 energy efficiency service suppliers and energy efficiency consulting firms active in Viet Nam, but the use of energy
performance contracting is very low (Vietnam Association of Science and Technology for Economical and Efficient Use of Energy Oct 2020
workshop). There are a number of barriers identified for this:
• Lack of legal framework to enable contracting modalities E.g. there are no guidelines on how to use ESCO services, no regulation on
intermediary organizations (third parties) to solve the problems arising between ESCOs and enterprises, nor are there regulations for state-
owned enterprises to actively and fully participate in the ESCO market.
• Access to finance for ESCOs is difficult due to high collateral requirements and low value of balance sheet
• No public procurement programs and government procurement guidelines and budgeting laws are unsuited for EPC procurement and allowing
ongoing payment from cost savings
• Industrial electricity tariffs that are low by regional standards
• EPC models are new in Viet Nam and therefore not trusted
• There are also credit risk concerns for the ESCOs extending credit to clients over long periods
VNEEP III has committed activities to address these barriers including establishing ESCO regulations, undertaking demonstration projects,
dissemination of best practice, and designing an energy efficiency fund.
Development partners are also implementing funding programs to support ESCO market development
•IBRD Project: Energy Efficiency for Industrial Enterprises US$102 mill credit line operational Q3 2018 to run to 2022. 13millUSD disbursed by Q2
2020
•GCF Project: EE Risk Sharing Facility for Industrial Enterprises US$86million risk facility backed by the GCF guarantee instrument to mitigate
credit risk of loans to industrial enterprises for EE, and thus encourage scaling-up of EE loans. Began implementation Aug 2020 for 15 year period
http://vepg.vn/wp-content/uploads/2020/01/VEPG_TWG2_2nd_Meeting_Report_14Sept2018_Final_compressed.pdf

II.c. Electricity market & renewable energy regulation
The Electricity Law 2004 set the goal for the transition to a market-oriented power sector. Structural unbundling proceeded since then to
pave the way for these market reforms with the vertically integrated utility, EVN, unbundled into subsidiaries including 3 generation
companies (GENCOs), the National Power Transmission Corporation, the National Load Dispatch Centre, Electric Power Trading
Corporation, and five regional distribution and retail subsidiaries (Power Corporations).
PM Decision 63/2013/QD-TTg approved the Road Map for Vietnam’s power market Development governing the pathway of the electricity
market with a long-term plan envisioning a completely competitive electricity sector, including wholesale and retail competition, by 2024
(figure below). At present Vietnam is in the process of moving to full operation of the wholesale electricity market (VWEM) stage from an
initial pilot. A pilot wholesale market has been operating in the country since 2019 which around 50% of large power plants by capacity are
actively participating.
Renewable IPPs do not participate in the spot market and are
not subject to price competition instead benefitting from
administratively set tariffs set out in standardized power
purchase agreements. The offtaker for the PPA is EVN’s
subsidiary Electric Power Trading Corporation. EPTC acted as
single buyer during the VCGM purchasing all power from
generators and providing power to the PCs under a Bulk Supply
Tariff. It is unclear whether renewable IPPs will participate in
the spot market in future for example under a contracts for
difference scheme linked to a competitive auction program.
https://www.adb.org/sites/default/files/project-
documents/48328/48328-001-tacr-en_0.pdf

As part of EVN’s unbundling process the majority of its generation assets
were structured into GENCO 1, GENCO 2, and GENCO 3, in preparation
for divestment to a holding rate of 51%, and full divestment by 2030.
Under this policy, EVN will retain ownership of strategic, multi-purpose
hydropower plants (those with dual use for flood control and/or
irrigation); However, the failed IPO of GENCO 3 in early 2018 and the
failure to attract strategic investors has put the divestment plans in doubt.
The majority of private investment into Viet Nam’s generation sector has
come in the form of Build-Operate-Transfer power plants procured under
PPP laws. These are restricted to large central fossil fuel plants that are
mostly directly negotiated and benefit from sovereign guarantees for
currency convertibility and payment. ‘
BOT = Build Operate Transfer; PVGas = PetroVietnam Gas; TKV = Vinacomin;
Evolution of the generation market structure to 2030
http://documents1.worldbank.org/curated/en/290361547820276005/pdf/133788-WP-
OUO-9-Vietnam-Energy-MFD-Report-ENG-for-printing.pdf
•Four projects that have been put into commercial operation (Phu My 2.2,
Phu My 3, Mong Duong 2, and Vinh Tan 1).
•Four projects under construction (Hai Duong, Duyen Hai 2, Nghi Son 2, and
Van Phong 1).
•Four projects in the stages of completing BOT contracts (Vung Ang 2, Nam
Dinh 1, Vinh Tan 3, and Song Hau 2).
•Two projects under negotiation (Quang Tri 1 and Dung Quat 2).
•Five projects at their initial stage, not yet negotiated (Long Phu 2, Vung Ang
3, Son My 1, Son My 2, and Quynh Lap 2).
https://uk.practicallaw.thomsonreuters.com/4-628-
5349?transitionType=Default&contextData=(sc.Default)&firstPage=true

The legal framework for procurement of renewable IPPs has been introduced sequentially from 2008 under various technology specific Prime
Ministerial Decisions and Circulars. These introduced administrative feed in tariffs and standardized power purchase agreements applicable to
specific technologies. Like other energy projects, renewables projects are obliged to comply with all relevant planning laws prior to implementation
and commercial operation. This includes inclusion in regional and/or national power development plan, securing relevant land use certifications,
securing construction and generation licenses, and securing enterprise and investment registration certification. The project approval process
requires the developers to engage at provincial and national levels, across different ministries and agencies and in addition the process is not always
consistently applied across the provinces. This has led to concerns at the complexity and opacity of the process.
Until this year the sole permitted offtaker in the standardized PPA EVN. There was therefore little regulatory room for business model innovation
for renewable energy developers such as direct supply to corporates or households. This position has recently loosened for solar projects with
Decision No. 13/2020/QD-TTg introducing for the first time a looser definition of the permitted offtaker of electricity. Accordingly, private
companies who are granted an operation licence for electricity distribution and retail will have the right to sell electricity from their solar installation
to end-consumers for the first time.
Circular No. 36 issued in 2018 on the procedure and order for issuance and withdrawal of power operation licenses provides an exemption in the
requirement for a generation licence for projects under 1MW capacity. There is also exemption for projects that are purely for self consumption.
Electricity generation licences are issued by MOIT, the Electricity Regulatory Authority of Vietnam (ERAV), or the relevant provincial People's
Committee (depending on the scale of the plant).
The authority responsible for granting a construction license depends on the scale, importance and corresponding classification of the project:
Special grade: Ministry of Construction.
Grades I and II: provincial-level People's Committees.
Grades III and IV: district-level People's Committees.
Circular No. 03/TT-BXD Regulation on classification of construction works and instructions on application to construction management

II.d. Smart grid, demand side management, & distributed
energy
http://documents1.worldbank.org/curated/en/757761583166223011/pdf/Learning-from-Power-Sector-Reform-Experiences-The-Case-of-Vietnam.pdf
The technical performance of Vietnam’s power system has significantly improved since the 1990s. Current total transmission and
distribution losses are 7.6 percent (2019), which is low compared to similar countries and systems. This reflects the strong operational
performance and capacity of EVN and its transmission and distribution subsidiaries. The quality of service in electricity supply to
consumers has steadily improved with less frequent power interruptions with lower duration

energy
As with energy systems across the world, the incumbent transmission
investment planning and network designs were established under the
standard model of large-scale centralised base load power stations. Due to
the rapid integration of variable and non-dispatchable solar generation
sources in 2019 (see graph to right) the transmission system came under
significant strain with some areas experiencing congestion and curtailment.
It is critical for the next phase of renewable generation deployment under
PDP VIII that investments in grid upgrades can keep pace to ensure
flexibility and smart controls while facilitating inter-regional power
transmission from the south where renewable resources are of the highest
quality to load centers in the North.
The government has established a number of policies and programs in this
area: On 08 November 2012, Prime Minister issued Decision No. 1670/QD-
TTg approving the Scheme on Intelligent Power Grid in Viet Nam (known
as the Smart Grid Roadmap). This scheme aims “To apply the intelligent
Power grid technology in order to connect, operate stably new and
renewable energy sources aiming to facilitate to exploit effectively,
contribute in encouraging development, increasing rate of power sources
using new and renewable energy, contributing in environmental protection,
assurance of national energy security.”
This includes deployment of SCADA control systems, remote monitoring
and controls.

energy
These earlier demand side pilots are now being built
on with Decision 279/2018 launching the national
Demand Side Management program for the 2018-
2030 period. And its implementation plan (Decision
175/2019)
Significant implementation progress has been made including:
New SCADA/EMS equipped in National Load Dispatch Center (2016) – Activated functions: State estimator, Automatic Generation Control (AGC),
Open OTS, Open SOM
SCADA connection (03/2019) – Big Power Plant (over 30MW): 99% connected (4% temporally lost connection) – 500kV Substation: 100% connected
– 220kV substation: 100% connected (2% temporally lost connection) – 110kV substation: 96% connected (7% temporally lost connection)
Remote metering (12/2018): – 99,7 % power plants – 100% substations (from 110kV and above) – 35,6% customer meters
In 2015, Ho Chi Minh City Power Corporation implemented successfully the Demand Response Pilot Project that included 02 programs : Curtaible
Load Program – CLP. & Voluntary Emergency Demand Response Program – VEDRP.
Slide 1 (german-energy-solutions.de)
In 2015, Ho Chi Minh City Power Corporation
implemented successfully the Demand Response
Pilot Project that included 02 programs :
Curtailable Load Program – CLP. & Voluntary
Emergency Demand Response Program – VEDRP.

energy
By Sep 2020 there were 50,000 operational rooftop solar projects with a combined capacity of about 1,200 MWp, Electricity of Vietnam (EVN)
This impressive development in distributed generation is thanks to a supportive regulatory framework A net metering regime was established
under Decision No. 11/2017/QD-TTg and its implementation circular No. 16/2017/TT-BCT. This set out the requirement for bidirectional
metering and annual balance payments from EVN to the installation owner at the rooftop Feed in Tariff rate. Decision No. 02/2019/QD-TTg
changed the trading method replacing the net-metering method with direct consumption-direct supply method due to issues with payment
calculations and disbursements
Latest standardized PPA for solar announced in Decision No. 13/2020/QD-TTg has also opened up additional options for distributed business
models including leasing and PPAs with corporates. With support of USAID MOIT is also launching a pilot program for synthetic PPAs which
will enable corporate sourcing of off-site renewables through a synthetic PPA. This will allow corporates to hedge power price risk and achieve
sustainability targets while allowing developers to benefit from revenue certainty and more flexibility in the PPA terms compared to the
standard PPA with EVN as counterparty.
Viet Nam’s Rooftop Solar Promotion Program for 2019-2025 was launched by the Ministry of Industry and Trade’s (MOIT)
Decision 2023/QD-BCT, targeting 1 GW of rooftop solar capacity in the form of 100,000 rooftop systems by the end of 2025.
With support from USAID the program has a number of components:
- Continued development of rooftop solar supporting policies & regulations
- Researching and developing standards, codes, and guidelines for technical equipment and procedures for
inspection & enforcement
- Conducting market research and Implementing pilot support programs and projects on investment and technical assistance
- Implementing a Training and Certification program for equipment providers, consulting service providers;
organizations and installers
- Developing an online database on solar power and rooftop solar in order to support the management, planning and
monitoring of the market

energy
On 21 January 2020 in Proposal No. 544/TTr-BCT,
MOIT submitted its proposal for direct PPA pilot to
run until 2023. The pilot will target 150-300MWp of
capacity with each projects within 5-50MWp.
The pilot will test a a synthetic PPA whereby the
generator will export power to the grid at wholesale
spot prices while also signing a contract for difference
PPA with an agreed strike price with the corporate
counterparty. Under these terms if the wholesale
price is lower than the strike price the corporate off-
taker will make payments to the generator of the
difference and vice versus if the wholesale price is
higher than the strike price. Renewable generation
certificates will also be exchanged from the generator
to the off-taker in this arrangement.

III. INVESTMENT & COMPETITION POLICY

III.a. Creating a level playing field between public and
private investors in clean energy infrastructure
Since the passing of a new constitution in 1992 that
permitted private ownership, the electricity sector
has seen significant reforms transforming the
sector from a centrally planned state monopoly to a
power market with private sector participation in
power generation, and with multiple competing
participants buying and selling power. From 2004,
following the passage of the Electricity Law,
competition and new market structures have been
gradually introduced. The competitive generation
market began full operation in 2012 and the
wholesale electricity market is planned to begin full
operation by 2021 after a successful pilot phase.
The legal and institutional reforms underpinning
this drive to market liberalization are presented in
the diagram to the right.
http://documents1.worldbank.org/curated/en/757761583166223011/p
df/Learning-from-Power-Sector-Reform-Experiences-The-Case-of-
Vietnam.pdf

Vietnam’s electricity sector reforms have been remarkably successful and have led to impressive social and economic outcomes with regards to
energy access, infrastructure investment, and sector efficiency. However the electricity sector still bears many characteristics of a vertical
monopoly model with EVN remaining as a dominant power generation unit, operator of the sole power trading unit (power trading company),
transmission unit, and electric system and market operating unit. Accordingly, the vertical linkage between EVN’s units at all the stages of the
electricity industry (power generation, transmission, distribution, and retail) may create competitive advantages for EVN-affiliated companies and
restrict fair competition. To deliver the next stages of market liberalization reforms set out in the power sector reform roadmap and facilitate
increased participation of the private sector in the generation market (and ultimately in the retail market) the government has recently undertaken
a number of important reforms to improve SOE governance and improved institutional structures for market operation.
• Under current plans EVN’s National Load Dispatch Center, which acts as System and Market Operator (SMO), will be converted to an
independent accounting unit of EVN by 2021, and by 2025 will be fully separated from EVN, while remaining under government control. This
will ensure greater operational independence and build trust in fair power dispatching and spot market operation.
• Introduction of a new competition law in 2018 and the establishment of the National Competition Committee provides a clear legal framework
for the regulation and enforcement of abuse of market power
• The Enterprise Law (2014), Investment Law (2020), and the Law on Management and Use of State Capital Invested in Production and
Business (2014) all strengthen corporate governance and reporting requirements of SOEs to improve transparency, efficiency, and
accountability
• Establishment of The Commission for the Management of State Capital at Enterprises (CMSC) under Decree No. 131/2018/ND-CP to
strengthen supersivion and management of 19 SOEs (inc. EVN). This added supervision seeks to improve compliance with regulations related
to the use of capital and assets with the overall aim of enhancing financial transparency
• The use of state capital in the electricity generation sector is gradually being reduced with divestment of EVN GENCOs with the aim of full
private ownership by 2030 (EVN will retain sole ownership of strategic generation assets and transmission and distribution infrastructure),
Despite the ‘equitization’ process hitting challenges due to investor questions on profitability and asset valuation the government is refocusing
efforts to facilitate this process. Circular No.21/2019/TT-BTC provides a framework for book building in line with global best practice whereas
Circular No.03/2019/TT-NHNN allows overseas investors to make deposits in foreign currencies when signing up for SOE auctions

IPP Procurement
• Viet Nam recently ratified a consolidated PPP law (No. 64/2020/QH14) which comes into effect on Jan 1st 2021. This law brings together a
complex set of legislative documents to set out clear and transparent rules for tendering, bidding management, evaluation and selection of
goods & service providers including for fossil fuel power projects under PPP contracts.
• The PPP legal framework has not been applied for competitive selection of renewable IPPs to date. Renewable IPPs are procured through
private investment arrangements under the FiT regulations. This procurement framework has generally been considered negatively by
private participants who see the project approval process (such as securing inclusion on provincial and national power development plans) as
being overly complex and opaque, with many steps, different stakeholders, and different procedures applied across provinces.
The government is committed to introduce structured, competitive procurement programs for renewable energy IPPs in the near future. A pilot
solar auction is planned in 2021 and decision 39/2018/QD-TTg mandates MOIT to develop a proposal for a wind auction mechanism to be
applied by November 01, 2021. Additional legal guidance will need to be developed within the existing law to enable competitive auctioning.
World Bank are supporting the government on the solar auction pilot and have recommended that IPP-specific bidding regulation be added to
either the investment law, the bidding law or the PPP law. Alternatively, the Prime Minister could issue a Decision to host the competitive
selection regulations under the current MOIT renewable support framework. An additional issue is that the current prescriptive form of planning
under the PDP process affords little flexibility for competitive selection.
http://documents1.worldbank.org/curated/en/949491579274083006/pdf/Vietnam-Solar-Competitive-Bidding-Strategy-and-Framework.pdf
Decision No.3771/QD-BCT on functions, responsibilities, authorities and organization for inspection & dispute resolution in electricity activities
defines ERAV as the primary dispute resolution authority for IPP procurement. If a resolution is not reached between a private investor and
ERAV within 60 days the investor may seek resolution through the Vietnamese courts (international arbitration is not permitted under the terms
of the standardized power purchase agreement).
The electricity generation market structure is at risk of institutionalising a legacy of two parallel systems, on the one hand public generators
operating as merchant power plants, and on the other hand BOT and IPP plants that receive regulated set tariffs without exposure to market
prices. This may have negative impacts on the successful transition from a single buyer model to a fully functioning competitive electricity
markets that provides price signals which can drive more efficient capital allocation and plant operation.

III.b. Promoting equal treatment of foreign and domestic
investors in clean energy
Under the Investment Law (2020) & Enterprise Law (2014) the energy sector is treated as a permitted sector for foreign investment and therefore full
foreign ownership of clean energy assets is allowed. In terms of the legal framework regulating investment across the economy clean energy does not
face higher barriers to foreign investment compared to other sectors. However the requirement for an investment certificate approved by the
provincial departments of planning and investment, provincial chairman of People’s Committee, the Prime Minister, or the National Assembly
(depending on the scale of the project) is an additional regulatory step that foreign investors must complete compared to domestic investors.
Sectoral energy policy and regulation is applied equally to foreign and domestic investors however the content of the regulations has constrained
foreign investment from outside the ASEAN region. This is particularly due to the terms established in the mandatory, standardized power purchase
agreement that in many aspects falls below international standards of bankability. This includes for example the lack of a take or pay mechanism, this
has discouraged foreign investors and lenders whereas domestic investors have been more comfortable bearing curtailment risk exposure. Likewise,
domestic investors are more comfortable with EVN’s long-term creditworthiness as single offtaker for the PPA.
Concerns are also raised by foreign investors due to the complexity of the planning and approval process for clean energy projects. This has led to
concerns that without more transparent and simplified procedures the planning approval process may be dependent on personal relationships
The constitution does not allow private ownership of land in Viet Nam. The state administers all land on behalf of the people. The 2013 Land Law
allows the ownership of Land-Use Rights (LURs) but only for Viet Nam nationals. The State can lease LURs by contract to a foreign entity subject to a
land use rent (at reduced rates for renewable energy projects). Leasing is the only form of land ownership available to non-Vietnam nationals. Foreign
investors in Vietnam can also obtain LURs by way of a joint venture with a local Vietnamese partner who can contribute the LUR as a capital
contribution.
Foreign banks are not permitted to take security over immovable assets such as land use rights and assets attached to the land. This restriction gives
rise to complications in offshore financing by foreign banks. To overcome this issue transactions have been structured whereby local banks act in a
syndicate as security agents, it has been noted that the validity of this legal structure has not been tested or confirmed by Vietnamese courts.
https://www.hoganlovells.com/~/media/hogan-lovells/pdf/publication/taking-security-in-vietnam_pdf

III.b. Promoting equal treatment of foreign and domestic
investors in clean energy
The Politburo issued Resolution 50 in 2019 on “Orientation to improve quality and effectiveness in attracting and using FDI by
2030”, This resolution sets the priority to improve domestic enabling conditions to attract increasing levels of FDI. Although not
clean energy specific there is a clear priority set to further develop the legal frameworks in the country to overcome FDI challenges.
The Foreign Investment Agency (FIA), under the Ministry of Planning and Investment was established in 2018 and acts as a focal
point for facilitating inward and outward investment. FIA is responsible for a number of tasks including proposing solutions to
issues related to foreign investment and presiding over the development and implementation of foreign investment policy.
FIA also oversees the National Foreign Investment Information System which is a web portal giving information on procedures for
issuance of Investment Registration Certificates; posting and updating legislative documents, policies, investment conditions
applied to foreign investors; and updating information about investment promotion and foreign investment in Vietnam

III.c. Electricity market reform and status of roadmap
implementation
Decision No 63/2013/QD-TTg dated 8 November 2013 the Prime Minister
approved the power market roadmap establishing the overall plan for the market development
consisting of three major stages of reform:
• A generation competitive market introducing generation competition to sell to a wholesale
Single Buyer (the Vietnam Competitive Generation Market or VCGM), for the period 2011-2015;
• A wholesale competitive market (the VWEM), period 2015-2021; and
• A retail competitive market, from 2021 onwards (VREM).
https://www.adb.org/sites/default/files/project-
documents/48328/48328-001-tacr-en_0.pdf

implementation
The VCGM commenced full commercial operation on 1 July 2012. The intent of the
VCGM was to establish the rules and procedures for a single-buyer, cost-based
electricity market, to proceed with structural unbundling of EVN with the aim of
further market liberalization
This was done by having a single buyer,
the Electricity Power Trading Corporation
(EPTC), purchasing all power from
generators and providing power to the
Power Corporations (PCs) under the Bulk
Supply Tariff and the PCs selling power to
end use customers based on the uniform
retail tariffs
SPPA = standardized power purchase agreement
CfD = Contract for difference
BST – Bulk supply tariff
SMHP = Strategic multipurpose hydro power
TKV = Vinacomin
PV Power = Petrovietnam
PC = Power Corporation (EVN integrated
distribution and retail subsidiaries)

implementation
power costs for Power corporation changed
from the current bulk supply tariff (BST)
approach to a combination of transmission
charges, contract for difference payments
(SPPAs) and spot market payments.
MOIT Decision No. 8266/QD-BCT in 2015 approved the detailed design of
the wholesale market (VWEM). The design meant that EPTC no longer
acted as the single buyer of power from power plants participating in the
spot market. Power corporations were also permitted to directly contract
with generators with financial contracts for difference.
As a next step to supplement the legal
framework for implementation, the
Electricity Regulatory Authority of Vietnam
(ERAV) will have to formulate guidelines on
participation that apply specifically to non-
hydropower renewable power projects.
non hydro renewable generators are not
required to participate in the wholesale
market but are able to elect to under rules
announced in Circular 45/2018/TT-BCT
Have ERAV developed these guidelines?
http://documents1.worldbank.org/curated/en/949491579274083006/p
df/Vietnam-Solar-Competitive-Bidding-Strategy-and-Framework.pdf

IV. INVESTMENT PROMOTION AND
FACILITATION

IV.a. Carbon taxation and market instruments for valuing
carbon
In November 2020, a revised Law on Environmental Protection was announced, taking effect in 2022, establishing a emission trading
schemes for waster water and exhaust pollution. The Government will provide a roadmap and time for the implementation of the domestic
carbon markets in line with the country's socio-economic conditions and international treaties to which the Socialist Republic of Vietnam is a
signatory. An upcoming decree will specify targets, timelines and regulated industries.
The law legalizes enabling policies such as national greenhouse gas emission inventories, and the monitoring, reporting and verification of
emissions. Participating entities will be allocated emission quotas and will have the right to exchange and trade in the internal carbon market
country. The domestic carbon market will also include exchange of greenhouse gas emission quotas and carbon credits obtained from the
appropriate domestic and international carbon credit exchange and offsetting mechanism.
The Ministry of Natural Resources and Environment will be responsible for approving total amount of quotas by period, promulgating
regulations on the implementation of domestic and international carbon credit exchanges and clearing mechanisms establishing the domestic
carbon market. The ministry will also organize the allocation of greenhouse gas emission quotas and organize the domestic carbon market
operation. The fee for the allocation of greenhouse gas emission quotas is regulated by the Government.
The law states that the quotas will be determined as follows
• Greenhouse gas emission quotas will be determined as a function of the a) National strategy on climate change and other relevant
development strategies and planning; b) Inventory of national, sectoral, local and greenhouse gas emission facilities specified in Clause 4,
Article 93 of the Law; c) The roadmap and method of GHG emission reduction suitable to national conditions and international
commitments.
• Environmental pollutant emission quotas will be determined based on a) National socio-economic development planning and strategy; b)
Environmental zoning; c) National planning for environmental protection; content of environmental protection in regional planning,
provincial planning; d) The load-bearing capacity of the environment in the waste receiving area; d) Environmental technical regulations.

IV.a. Carbon taxation and market instruments for valuing
carbon
Until the revised Law on Environmental Protection takes effect in 2022,
carbon is only indirectly priced through the environmental protection tax
rates which are not based in policy rather a cost of carbon. Viet Nam is one of
the first countries in South East Asia to put in place an environmental tax
instrument, contributing towards Viet Nam’s commitments towards the
international community regarding climate change, and the national green
growth strategy. The Law on Environmental Protection Tax passed in 2010,
and established an indirect tax on polluting products and goods such as coal
and oil-based fuels, plastic bags, pesticides and other chemical products. In
2012, the government received 1-2% higher tax revenues and carbon
emissions decreased by 1.7% compared to BAU, highlighting the immediate
benefits of this program.
The ETP was applied to Hydrochlorofluorocarbon (HCFCs) contributing to the
achievement of Viet Nam’s commitment of complete phase-out of HCFCs by
2030 under the Montreal Protocol on Ozone-Depleting Substances

IV.a. Fossil fuel and electricity tariff subsidies
The Government of Viet Nam has taken actions to reduce direct subsidies in the energy sector and move
increasingly towards market mechanisms for the pricing of energy products. There are currently almost no
direct subsidies for energy products apart from small subsidies targeting poverty reduction; including modest
electricity subsidies for impoverished households and smallholder farmers, and diesel subsidies for households
involved in artisanal fishing. The Green Growth Strategy and Climate Change Strategy both set targets of
phasing out subsidies by 2020.
Circular 83/2014/NĐ-CP dated on 03 September 2014, determines that prices of gasoline, diesel and other
petroleum products are linked to the international market but regulated by the government. The same is set
for natural gas and coal prices. Decision 24/2011/QĐ-TTg dated on 15 April 2011 also determine that electricity
prices should follow market mechanisms.
In reality, however, it is unclear how closely fossil fuel prices follow the international market, given that fuel
price adjustments for domestic oil, gas and coal producers beyond a designated threshold have to be approved
by the government, and prices of fossil fuel inputs into the electricity sector are subject to ministry-imposed
ceilings. Given that block electricity tariffs are also set by the government, and broadly acknowledged to be
priced precariously low for recovering investment costs, there are significant implicit subsidies to electricity in
Viet Nam.
Although direct fossil fuel subsidies have been restricted, tariff price controls account for a large source of
indirect subsidies. This is notably important industrial sectors, as industrial energy use has increased almost at
the same rate as GDP. Given the low tariff price, energy consumption of these industries is to some extent
subsidized, which means that firms can opt to use more energy rather than invest in more effective or efficient
machinery and equipment. Viet Nam has committed to reforms in the electricity market seeing the gradual
introduction of a competitive electricity retail market from 2021-2025. This will require a loosening of tariff
controls to allow market-based pricing and will be introduced for large consumers as a priority.
Question/Comments
• Are level and efficiency of fossil fuel
subsidies monitored on a regular
basis? (only for indirect subsidy)

IV.b. Targeted incentives - Feed in Tariffs
In order to promote investment in power generation from clean energy, the government introduced avoided-cost-tariffs and Feed in Tariffs (FiT)
which provide long-term, administratively set tariffs.
Since 2008, renewable energy projects have been procured under avoided costs tariffs and feed-in-tariffs schemes. The avoided cost tariff are
applicable for small hydropower and biomass projects with the tariff determined as the production cost per kilowatt-hour of the most expensive
power-generating unit in the national power grid. These are set by regions and vary by seasons and daily dispatch periods. In 2019, MOIT issued
Circular No. 29 amending the avoided cost tariff mechanism for small hydropower projects, limiting eligibility to single hydropower plants of up to
30MW capacity.
For other technologies a FiT, has been established, which fixes the export tariff paid to renewable energy producers. The FiT is fixed for 20 years and
is not indexed for inflation. Current FiT schemes include grid connected, rooftop, and floating solar (ending in 2020), onshore wind, offshore wind,
biomass combined heat and power, waste to energy, and landfill gas.
Standardized Power Purchase Agreements are mandatory for all renewable energy projects eligible for feed in tariff rates.
FiT schemes have seen mixed results. Given the already low electricity tariffs in Viet Nam, renewable energy FiT have been noted to be amongst the
lowest in the world. The rate is fixed to US dollar value but is denominated and paid for in Vietnamese dong adjusted to the exchange rate
announced by the State Bank of Vietnam on the invoice date. This exposes foreign investors to currency inconvertibility risk with limited, affordable
options for mitigation through guarantees. The solar FiT scheme was a great success notably amongst domestic developers and led to a boom in
projects. Capacity deployment in 2019 exceeded PDP 2020 targets by over 500% 850 MW compared to 4.5 GW operational by July 2019. However,
the wind FIT, introduced in 2011, as too low to drive investment and it was later revised in 2018 with a higher tariff differentiated for onshore and
offshore projects/ .
The Feed in Tariff scheme for each technology has a built in time limit for connection to grid. In some case this has led to a rush to develop project
and certain projects have not been able to make these deadlines. This situation was exacerbated in 2020 due to the COVID pandemic. For wind the
initial timeline proposed was criticized for being too short for adequate project development and gird connection.

IV.b. Targeted incentives - Feed in Tariffs

IV.b. Targeted incentives - standardized power purchase
agreements
MOIT has issued model forms of PPA for small hydro, wind, biomass waste-to-energy and solar. The guidelines for wind, biomass, waste to energy
and solar are laid out by respectively by Circular No. 02/2019/TT-BCT, Decision No. 08/2020/QD-TTg, Circular No. 32/2015/TT-BCT, and Circular No.
18/2020/TT-BCT. These PPAs have a term of 20 years and are non-negotiable.
The PPA for small hydro is determined by Circular No. 29, with a maximum duration of 12 years for the application of the avoided cost tariff with
risk-sharing mechanism.
Feedback on the model PPAs for solar and wind has highlighted issues around bankability from the perspective of international lenders, leaving
investors open to several risks including, risk of grid failure, curtailment, changes in law, early PPA termination, and off taker breach.
• Developers are responsible for transmission and grid connection costs up to the point of interconnection and must make a separate grid
connection agreement.
• There is no take-or-pay obligation or minimum purchase guarantee. The New Model PPA for solar has particularly been scrutinized by investors
for the removal of EVN’s offtake obligation of to purchase the entire power output generated from the renewable power projects, which may
inconsistent with Decision No. 13. This creates contractual uncertainties, given curtailment risks and limited transmission capacity that
developers are facing.
• The model PPA does not contain protection in cases of changes in law.
• There is also concern over compensation payment on termination, which aims to manage the risk that should the PPA be terminated without
fault on their part. Compensation was initially limited to the value of electricity generated during the previous year, then broadened in new
PPAs to restitution and expectancy damages. However the burden of proof for damages and lost direct benefits remains with the seller and the
question remains as to whether the damages recovered will be sufficient to cover costs and expected returns.
• Liability exemptions in cases of force majeure events will not include "liability in relation to payment of amounts due under the PPA before the
point of time when such event of force majeure occurs”. In cases of prolonged force majeure of at least one year, the parties shall negotiate on
an appropriate and reasonable solution to address the force majeure event and its effects. This does not however clarify with respect to
compensation.
• There is no government guarantee of EVN’s obligations under the PPA.

IV.b. Targeted incentives – fiscal incentives
Renewable projects fall within environmental activities and benefit from fiscal incentives:
• Corporate income tax preferences:
• Full exemption for the first 4 years followed by a 50% reduction in the next 9 years.
• Rate of 10% for the first 15 years on income from new investment projects for renewable energy production, which may be extended to
up to 30 years in
• certain cases
• Import duty preferences: on imported goods to establish project fixed assets, materials and semi-finished products that are not domestically
produced; projects are also entitled to exemption from import duty for 5 years upon commencement of production in respect of raw materials
and components imported for production of the project which cannot be produced domestically.
• Land related incentives: investors may be entitled to exemption from the land use fee that would usually apply for 11 years or, in cases where
the investment project is in a region facing extreme socio-economic difficulties, 15 years.
• Exemption from land rents and water surface rents: during capital construction period of a new building or plant for up to 3 years from the
effective date of the land lease contracts (Investment law, Decree No. 04/2009/ND-CP)
Owners of renewable energy projects can obtain preferred loan rates of up to 70% of the total investment cost at an interest rate equivalent to
that of a 5-year government bond plus 1% per year, from the Vietnam Development Bank (VDB) or the Vietnam Environment Protection Fund
(VEPF). The maximum term of such loan is 12 years. They can also apply for interest support from the VEPF. (Decree No. 151/2006/ND-CP /Decree
No. 106/2008/ND-CP/ Decree No. 151/2006/ND-CP)
The VEPF may offer subsides for electricity generated from solar wind geothermal, tidal or methane, if production costs are greater than sales price

IV.b. Targeted incentives
MPI and local investment promotion offices provide information and explain regulations
and policies to foreign investors. Furthermore, the semiannual Vietnam Business Forum
includes meetings between foreign investors and Vietnamese government officials which
allow direct engagement and dialogues, and has been noted by foreign investors to have
helped address obstacles
All legislative document, including those on foreign investment are published publicly in
the relevant official gazettes and/or local media channels(Law on Promulgation of legislative
documents No. 80/2015/QH13) Vietnam maintains a national online database of legislative
documents. At the central level, the official gazettes of the Government are available on the
website of the Official Gazette, managed by the Office of Government. At the provincial level,
the official gazettes are also available on official websites of most of the provinces, managed
by the Office of the relevant provincial-level People’s Committees. Unofficial English
translations of renewable energy and energy efficiency related legislation are available on the
Viet Nam Energy Partnerships Group website and have been provided by GIZ.
Protection against retroactive policy changes affecting tariffs or support schemes. The
model PPA does not contain a law stabilisation provisions, however, the Law on Investment
includes a provision for investment guarantees in the event of changes in law or policies.
At present, there is no codified law on administrative procedures in Vietnam, but fair process
is guaranteed in other laws or regulations. Administrative procedures are dispersed in laws
and regulations of specific business sectors. Vietnamese laws have certain provisions to
ensure fair process, such as the procedures of the Law on Administrative Sanction and Law on
Complaints.
Institution providing project preparation support
(financial and technical) to ensure bankability of projects.
The foreign Investment Agency (FIA), a national-level
administrative agency, overseen by the MPI, works as a
focal point and facilitator for foreign investment. The
World Bank worked with MPI to establish in 2013 a Project
Preparation TA Facility.
A pipeline of prioritised energy projects is published in
sequential Power Development Plans. The current plan is
the Revised PDP VII covering the period up to 2020. The
PDP VIII covering the period of 2021-2030 with a vision to
2045 is currently being developed

IV.b. Targeted incentives – renewable energy certificates
and capacity auctions
Renewable energy certificates have not yet been implemented in Viet
Nam, however these incentives are proposed in the Vietnam Renewable
Energy Development Strategy 2016-2030 with outlook until 2050 (REDS).
The strategy indicates that a Renewable Portfolio Standard (RPS) will be
introduced as a policy mechanism to guide the deployment of renewable
energy generation.
Large power generation companies with an installed capacity of larger than
1,000 MW, and distribution companies must source at least 3%, 10% and
20% of their electricity from renewable sources by 2020, 2030 and 2050
respectively.
Renewable energy capacity auctions have not been launched but the
government of Viet Nam is planning to transition away from a FiT regime
towards competitive auctions. The Prime Minister confirmed this decision
in December 2020, after months of uncertainty over the future of
renewables.
• Decision 11/2017/QD-TTg required MOIT to evaluate and plan for the
development of a solar auctioning mechanism. Accordingly, two
programs related to solar auctioning are currently underway.
• Firstly, a pilot auction for a total of around 400MW of floating
solar capacity is planned for implementation 2020-2022 with
the support of ADB.
• A wider program of solar auctions is also planned with support
of World Bank and GEF.
• According to Decision No. 39/2018/QD-TTg of 2018, MOIT will submit
a policy introducing an auction process for the selection of new wind
power projects and tariffs from November 2021.

IV.d. Corporate sourcing of renewable energy
In 2020, MOIT submitted proposal No. 544 Draft DPPA Decision for a pilot
direct power purchase agreement (DPPA) mechanisms between renewable
energy developers/power generation companies and private power
buyers/consumers (Draft DPPA Decision). MOIT is proposing a synthetic DPPA
mechanisms (also known as financial, virtual direct or corporate PPAs) for off-
site renewable energy projects. ERAV have also reviewed the Sleeved DPPA
option but the synthetic DDPA better suited the pilot programme. The
proposal and draft decision propose specific mechanisms for the pilot DPPA
program, as well as scope, scale and objectives, to be implemented between
2020 and June 2022.
• Proposed scope: to be applied nationwide with a limited total size
ranging from 400 MW to 1,000 MW. This aims to balance the
government’s ability to control and manage the pilot, whilst also making
it large enough to incorporate large power consumers and to assess
effects and difficulties
• Proposed criteria for participating GENCOs: limited to grid connected
solar and wind generators over 30 MW and included in the PDP
• Proposed criteria for participating private power consumers: limited to
power consumers for industrial manufacturing, Purchasing electricity at a
voltage level of 22 kV or larger.
• Proposed registration on electronic platform, assessed and selected
based on MOIT criteria assessment and final selection publicized on
electronic information portal
The process for industrial and commercial users to source electricity directly
from IPPs or investing in their own renewable electricity generation is
currently very complicated in Viet Nam. Although, Government policies have
made conditions more favourable for renewable energy, there are still
challenges for companies to directly source renewable energy. To support the
development of corporate sourcing of renewable energy an initiative named
VIET NAM CORPORATE ENERGY LEADERS (VECL) was co-founded by WWF and
the Vietnam Business Council for Sustainable Development under the Vietnam
Chamber of Commerce and Industry (VCCI), in partnership with the Clean
Energy Investment Accelerator (CEIA).
According to VCCI, VCEL will create a corporate community to share information,
experience and learning, while providing market intelligence and local expertise
to inform decision making and build renewable energy awareness and capacity.
Earlier programmes to educate and inform large consumers about the benefits
and costs of renewable electricity include the 2017, the USAID Vietnam Clean
Energy Program under which local authorities receive technical support and
training to improve data management, collection and analysis capability in
construction, encompassing power usage in office buildings, hospitals, hotels,
apartment buildings, schools and commercial buildings. This programme was
implemented by Winrock International, launched the first Green Growth Action
Plan (GGAP) for the Vietnam construction sector, which was developed jointly
with the Vietnam Ministry of Construction to strengthen the foundation for low-
emissions energy systems in Vietnam’s construction sector (VCEP 2015).

IV.e. Public procurement and facilitation of energy
efficiency Info missing
Do public procurement programmes for energy efficiency exist? Which sectors or end uses
have been covered or are being considered?
Info missing
How are such programmes financed and implemented?
The Vietnam Energy Efficient Public Lighting progamme (US$15 million), funded by the Global
Environment Facility, UNDP, central and local government, and the private sector, to install and
promote the use of energy efficient lighting across the country.
Have these programmes been successful at driving down the cost of energy efficiency
investments?
Question/Comments
Need more inputs on this lighting project.

V.a. Access and status of finance for clean energy
The financial market remains highly concentrated around bank credit, with a relatively small capital market.
Financing is heavily reliant on the bank credit. Lending for clean energy projects however remains low. Bank portfolios are dominated by public
sector, including SOEs, and consumer lending, which crowds out private ventures. [to complete paragraph with more information on Private sector
debt, banking sector size and fragmentation, commercial banking (capital adequacy ratio, non-performing loans]
Long term credit to firms is constrained by the short-term nature of banks’ deposits and high transaction costs. However, this has not prevented
domestic banks from providing long term loans up to 10 years lots of credit. It is however a source of systemic risk in the financial sector and which
SBV are wary of with new regulations tightening the proportion of short term capital allowed to be committed to long-term lending. (Circular 8 sets
maximum ratio of short-term capital sources for medium- and long-term lending from 40% in 2020 to 30% in 2023)
There is rising interest in green lending amongst Vietnamese banks but barriers include inadequate capacity for processing green credit
appraisals, such as risk assessment and evaluation of new technologies. Interest rates remain relatively high. Green credit programmes now exist to
facilitate finance for RE projects and green SMEs. At the start of 2019, there were 20 credit institutions providing green credit loans with a lending
balance of VND242,000bn, an increase of 2% compared to 2018 .
Debt and equities are emerging as a solution for financing longer-term and riskier projects but the financial market is immature, with a small
market size and undiversified financial instrument types.
Some refinancing has taken place from development banks. For example, EVN the Da Mi floating power plant, was re-invested in after operation
by the ADB. But refinancing remain limited. Banking regulations do not permit securitized instruments, restricting the options to offload long-term
debt and recycle capital. On the developer side - the domestic bond market is not established and is not a realistic source of long-term capital for
refinancing. Government are trying to develop the bond market with the orientation away from banks focusing on shorter term lending over the
construction period.

International investors in clean energy remain scarce, less comfortable with the risk environment.
Over 15 billion USD will be required between 2021 and 2030 alone, in order to reach the 2050 strategy of at least 43% renewable capacity (PDP 8).
Investments in conventional power plants and hydro power plants has tended to rely on domestic public sources of financing. With public debt
close to a legal ceiling of 65% of GDP, private sources of finance have a bigger role in these types of projects.
Renewable energy under FiT has tended to be financed domestically through pure equity or equity and bank credit. A sharp increase in private
finance in 2019 was triggered by interest in the solar FiT scheme, drawing in local and regional investors, but little to no international investors.
Regulatory frameworks for IPP investment and relevant financial systems are still relatively immature, discouraging international investment.
This is linked to investor confidence in the creditworthiness and investment capacity of EVN. The BB credit rating received in 2018, has gone a long
way to facilitate borrowing from international markets. Electricity reforms should see the gradual introduction of a competitive electricity retail
market from 2021-2025 to allow market-based pricing, but to date, government tariffs controls maintain electricity prices at very low levels by
international standards. Grid investment have also been insufficient relative the fast pace at which renewable capacity is increasing.
Financing costs remain relatively high and international banks are reluctant to lend to the sector. Restriction on foreign banks taking security over
immovable assets.
There is also a potential risk associated with bankability of projects, notably regarding dispatch unreliability, no government guarantee, potential
legal disputes and lack of international arbitration, no take or pay in PPA agreements, uncertain PPA termination payment amongst other PPA terms
discussed in chapter 4.
There is limited project finance in Viet Nam. There is no single or consolidated legal instrument that specifically governs project finance in Vietnam.
This is also a question of lending risk as a non-recourse structure is very difficult with so much revenue risk stacked on the project. This stems from
the PPA bankability. Vietnamese banks are also not experienced in structuring non-recourse project finance and underwriting based on project
fundamentals rather than balance sheet. Clean energy project lending has mostly been successful with the involvement of international financial
institutes or donors. Corporate finance play a large role for local firms in funding clean energy projects.

Viet Nam has recognized the potential of the capital market for long term and diversified funding.
As Viet Nam graduates from foreign aid and concessional loans, the capital market represents an opportunity to fill the financing gap. The size of
the capital market is still lagging behind ASEAN countries, despite having grown significantly, reaching nearly 100% of the GDP in 2019. Several
government strategies and plans look towards developing the capital market:
• The National Strategy for Green Growth 2011–2020 also focuses on green finance and green financial products for the Viet Nam stock
market.
• The Vietnam Bond Market Development Roadmap 2017–2020 is one such measure aiming to develop the bond market.
• The decision to fix a 20 years contract period for the FiT provides long-term revenue potential of the PPA, well suited to fixed income
investors. However, the PPA does not provide certainty of revenue given curtailment risk and offtaker credit risk.
A limited number of pooled investment vehicles exist to support clean energy projects, notably in areas where capital remains scarce in the face
of high risk and considerable financing costs. These investment vehicles can be particularly important in early stage finance where risks are the
greatest.
• The Dragon Capital Mekong Brahmaputra Clean Development Fund L.P., an ABD fund focusing on Energy Efficiency and Renewable Energy
in the Mekong River Region, support Vietnamese projects in the early-stage funding, as well as financing.
• The Southeast Asia Clean Energy Facility (SEACEF), managed by Singapore-based Clime Capital, support Vietnamese projects in the early-
stage funding.
• The Armstrong South East Asia Clean Energy Fund is a private equity fund that invests in small-scale renewable energy and resource
efficiency projects in Southeast Asia, including Vietnam.

V.b. Strengthening and deepening local financial markets
Current status of local finance markets and ability to meet needs
Currently government bonds dominate the market, with corporate bonds growing at a slower rate (9% of GDP in 2018) and a preference for short
maturity bonds. Corporate bonds are issued in the private placement market, limiting participation from institutional investors, due to limited
information, disclosure and transparency. No project bonds
Vietnam’s equity market has been used to raise capital directly by only a few companies, despite outperforming other ASEAN markets in its growth
in recent years. Additionally, investors, especially foreign investors, face challenges in information disclosure. Information provided in English to
foreign investors in a timely manner can further limit foreign investment.

V.b. Strengthening and deepening local financial markets
Pension funds. Vietnam Social Security (VSS),
Department of Fund Management and Investment, is
being supported by the World Bank on training and
improvement of pension fund governance. It seems that
pension funds are not actives in renewable energy
investment at this time. Do they invest in coal plants?
Why do they not invest in RE
Other institutional investors. There are about 40 local
and international asset management funds, including
equity investment funds, insurance companies and
sovereign wealth funds with total assets of more than
$4 billion. However, few investment funds focus on
infrastructure or hold a portfolio of infrastructure-
related assets. This is reflected that the local markets
lack of “quality” infrastructure assets that can meet the
investment requirements of the institutional investors
(UNESCAP, 2017).
The local financial markets have been identified in government strategy as being key to creating
financial resources for green growth.
The National Action Plan for Green Growth for the period of 2014 – 2020, and the National Strategy
for Green Growth 2011–2020 and the vision to 2050 are key drivers of this strategy. This includes a
focus on developing green finance and green financial products for the Viet Nam stock market. The
strategy prioritizes and allocates funding from the central and local budgets, especially for the
purpose of energy efficiency and renewable energy. It will also formulate mechanisms and policies to
stimulate green practices in financial institutions and enterprises. Most relevantly, the strategy
highlights using financial, credit and market-based instruments to promote and support the
development of the green economy and green products, moving towards a system for trading
certified greenhouse gas emissions, carbon tax and fees and levies. It also outlines encouraging
mobilizing loans, ODA, technical assistance from countries, international organizations, and
Vietnamese intelligentsia living abroad and involve them in the implementation of the green growth
strategy.
The Bond Market Development Roadmap 2017–2020 with a vision to 2030 aims to develop the bond
market. The Roadmap aims at building a more sustainable market for medium- and long-term
financing, expanding the investor base, diversifying market products, enhancing market transparency
and adopting and aligning with international standards and practices. The government set a target
that the bond markets should reach 45% of GDP by 2020. As of September 2020, they had met 42%.
Vietnam has also been exploring green debt and equity instruments, supported by credit
enhancement mechanisms and other risk sharing approaches (partial credit guarantees for green
projects, concessional loans for solar energy projects, and risk sharing facilities for energy efficiency
projects).

V.c. Sustainable finance regulation, taxonomy
development and green bonds
Efforts have been made by the financial sector regulator and central bank made to promote sustainable finance.
SBV has been assigned to improve the institutional structure and enhance the financial credit capacity of commercial banks to facilitate green
growth, under Decision No.403/QĐ-TTg, implementing the National Action Plan on green growth period 2014-2020.
SBV is implementing capacity building for green credit and environmental and social risks management in the banking sector, and the review of
credit regulations to align with green growth objectives and targets, under Directive No.03/CTNHNN in 2015. This decision encourages the banking
sector’s credit granting activities of to take into consideration elements such as sustainable development, energy efficiency, national resources and
environmental protection in line with the National Action Plan on green growth period 2014-2020
Viet Nam requires credit institutions to report quantities and values of green loans, and design green lending policies for certain sectors, including
renewable energy, (Directive No 03/CT-NHNN). Listed financial institutions are also required to provide annual reports on initiatives related to green
finance and the share of green finance in their total investments (State Securities Commission’s Sustainability Reporting Handbook).
SBV has established sector-specific Environmental and Social (E&S) checklists. It also organizes technical training for Credit Institutions on E&S
risk management and due diligence. Directive No 03/CT-NHNN, requires all credit institutions formalize their E&S risk management, and
encourages commercial, co-operative, and foreign credit institutions operating to develop E&S risk management systems for lending activities.
Lenders are required to conduct frequent and periodic monitoring of borrowers’ own E&S risk management processes.

V.c. Sustainable finance regulation, taxonomy
development and green bonds
Green bonds are in pilot stage in Viet Nam
Local government green bonds have been piloted in Ho Chi Minh City
and Ba Ria Vung Tau for water management. No green bonds have
been issued for clean energy projects yet. No sovereign green bond
have been issued to date. However, the Vietnam Bond Market
Development Roadmap with a vision to 2030 has a focus on raising
capital for green projects.
The Ministry of Finance’s Decree 163 of 2018, relating to corporate
bond issuance, is considered the first-ever legal framework for
corporate green bonds in Vietnam. This decree relaxes issuance
conditions for corporate bonds and includes a tool to encourage
investment in green projects in the private sector.
Vietnam is also part of the ASEAN Capital Markets Forum, which has
released Green, Social and Sustainability Bond Standards based on the
ICMA’s Green, Social, and Sustainability Bond Principles.
Ministries have implemented a number of measures to support the
green bond market and the Ha Noi Stock Exchange (HNX) and Ho Chi
Minh City Stock Exchange (HOSE) have actively been working on
measures to attract investment. Role of development finance
Initiatives exist to provide guidance on clean energy investments,
sustainable finance and ESG principles.
Launched in 2017, this The Vietnam Sustainability Index (VNSI) takes
steps towards standardizing reporting of environmental, social and
governance-related performance for listed companies. The index aims
to identify ESG best practices implemented by public listed companies
in Vietnam, promote the adoption of ESG standards and best practices
among other listed companies, and create investment products to
attract responsible investors.
Viet Nam is a member of the Sustainable Banking Network, a
voluntary emerging markets network of financial regulatory agencies
and banking associations committed advancing sustainable finance in
line with international good practice, and in which one of the key
objectives is to improve ESG risk management.
Institutional investors adopted ESG principles??

V.d. Role of development finance
Development finance has had a significant role in funding clean energy
Bilateral and multilateral donors are the main source of public climate finance in Viet Nam. By 2017, the Support Program to Respond to Climate
Change (SP-RCC) distributed main climate funding with $240 million pledged by international and bilateral donor agencies towards the SP-RCC
(UNESCAP, 2017).
The Green Growth Strategy, includes a focus on mobilizing loans, ODA, technical assistance from countries, international organizations, and
Vietnamese intelligentsia living abroad and involve them in the implementation of the green growth strategy
Level of financial support for clean energy projects/ technologies covered. [notably historic investment in Hydro]
MOIT and Ministry of Finance are the National institutions responsible for development funding for clean energy projects.
Level of committed funding and instruments
Funds available to support project preparation and development of bankable feasibility:
The Dragon Capital Mekong Brahmaputra Clean Development Fund L.P., an ABD fund focusing on Energy Efficiency and Renewable Energy in
the Mekong River Region, and the Southeast Asia Clean Energy Facility (SEACEF), managed by Singapore-based Clime Capital supports
Vietnamese projects in the early-stage funding.
Viability gap funding (VGF) - The Coc San Hydropower project in Vietnam was successfully implemented through Viability Gap Funding. USD5m
grant from the Technical Assistance Facility by The Private Infrastructure Development Group (PIDG), in 2013. The finance helped to offset part
of the up-front preparation costs of pro-poor infrastructure investments in Coc San, Lao Cai province - the most mountainous area in Vietnam.
(This was not specifically labelled as a green deal; however, it was financing for a green project.) (climate bonds, 2020)
Blended finance mechanisms

V.c. Institutional innovation to promote clean energy
Role and impact of development banks
Role and impact of development banks
The Vietnam Development Bank (VDB) provides financial support to projects with a committed capital of USD 1.77 million in preferential credit
under a re-lending programme of the European Investment Bank (EIB) for climate change mitigation in Vietnam. VDB also holds charter capital.
At present, the VDB only provides loans for state investment credits and re-loan foreign investment (authorized by the Ministry of Finance for
subprime loans with risks) pursuant to Decree 32/2017 on investment credit and Decree 97/2018 on on-lending of official development
assistance (ODA) loans. (includes: projects invested in producing renewable energy, hydropower, wind power, solar power, geothermal, biomass
energy)
Vietnam Environmental Protection Fund: The VEPF is a state-owned financial organization established by the government. The VEPF holds total
chartered capital of VND 1 trillion, including VND 727 billion allocated by the state budget. One of the main activities of the VEPF is to provide
financial support for environmental protection, biodiversity, projects and activities at national, inter-sectoral and inter-regional levels on
environmental pollution prevention and recovery or severe local environmental issues (includes: deploying clean environment-friendly
technology, energy saving, producing renewable energy).
National Technology Innovation Fund (NATIF) is a state financial, non-profit institution that provides grants, preferential loans, subsidized loan
interest rates and loan guarantees, and financial support to organizations, individuals and businesses who carry out research, technology transfer
and innovation.
State banks such as Vietcombank, BIDV, and Agribank have a role in green crediting. For instance refinancing participating banks at lower
interest rates.

V.c. Institutional innovation to promote clean energy
Green banks
In August 2018, the State Bank of Vietnam (SBV) issued Decision No.1640/QD-NHNN approving the Scheme on the green bank
development in Vietnam. The overall goal of the Scheme is to accelerate the awareness and corporate responsibility of the banking sector
about environmental protection, the climate change response, directing credit resources into eco-friendly projects/programs, boosting
green production, services, as well as clean and renewable energy, in order to contribute to the promotion of green and sustainable growth.
The specific objectives and criteria of the Scheme include: increasing the ratio of lending to priority green industries and sectors;
accelerating the application of new technologies in combination with the development of environmentally-friendly practices and habits;
promoting e–transaction channels, new services and payment instruments on the basis of modern technologies; and ensuring that by 2025
all banks will have developed internal regulations on environmental and social risk management.

OECD-ENV Vietnam questionnaire key points

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