The question “must an FDI enterprise in Vietnam produce an ESG report” has a two-layer answer: there is not yet a standalone, consolidated ESG reporting duty for private FDI enterprises in Vietnam; but there is a set of component obligations on environment, emissions and disclosure that together form the “hard” core of ESG — and the rest arrives via the parent company, supply chains and capital markets, not via Vietnamese law.
Component obligations under current Vietnamese law
The first legal layer is operational environment: the Law on Environmental Protection 72/2020/QH14 and its guidance place environmental permits, monitoring and periodic environmental-protection reporting on production facilities — the raw data of the “E” pillar in any ESG report. The second layer is greenhouse-gas inventory: facilities on the list of GHG-emitting facilities subject to inventory issued by the Prime Minister (Decision 01/2022/QD-TTg) must conduct inventories and report emissions under Decree 06/2022/ND-CP (as amended by Decree 119/2025/ND-CP) — a duty that lands directly on FDI plants in energy, steel, cement and chemicals (see FDI-LC-2041 on the carbon market). The third layer applies only to public companies: the annual report under Circular 96/2020/TT-BTC contains a section on the company’s environmental and social impact — an early-form ESG disclosure, but mandatory for that group. Beyond these three layers, no instrument currently requires a private FDI enterprise to publish a standalone “ESG report” or sustainability report under one unified standard.
Which standard to use, and what it actually costs
Where the duty comes from the group and the market, choosing a standard is the company’s decision — and should follow the primary reader. GRI Standards are the most common framework in Vietnamese practice for stakeholder-oriented sustainability reporting. IFRS S1 and IFRS S2 of the ISSB are the investor-oriented sustainability and climate disclosure standards; in Vietnam, the Ministry of Finance is implementing a roadmap toward international sustainability-disclosure standards on a voluntary basis in the initial phase — FDI firms whose parents apply ISSB should build compatible data structures early. For groups headquartered in the EU, the heaviest practical demand comes from CSRD/ESRS at group level: the Vietnamese subsidiary is not itself “subject” to CSRD, but the parent will require ESRS-format data (Scope 1–2–3 emissions, labour, supply chain) on the group’s timetable. On cost: there is no statutory fee for an ESG report; actual costs comprise data-system and reporting consultancy, the GHG inventory (if in scope), and — where the market demands it — independent assurance of the report. Treat every quoted “market price” as a commercial reference, not a rule. Practical advice: start from the obligation data you already produce (environmental reports, GHG inventory, HR/labour data), build one minimum ESG dataset reusable across frameworks, and expand disclosure scope only once the reader is identified: the parent, a bank, or EU customers (see FDI-LC-2039 and FDI-LC-2040 on the two mechanisms — carbon and supply chain — turning ESG data into a commercial condition).
Frequently asked questions
Must an FDI enterprise produce an ESG report?
There is no standalone consolidated ESG reporting duty for private FDI in Vietnam yet. Current duties are components: environmental permits and reports under the Law on Environmental Protection, GHG inventory if on the Decision 01/2022/QD-TTg list, and — for public companies — the environmental-social section of the annual report.
Which standard applies to an ESG report: GRI, ISSB or ESRS?
It follows the primary reader: GRI is common in Vietnam for stakeholder-oriented reporting; ISSB IFRS S1/S2 are investor-oriented and on the Ministry of Finance’s voluntary-phase roadmap; ESRS is mandatory at EU group level under CSRD — the Vietnamese subsidiary typically supplies ESRS data to its parent. Many groups keep one dataset and present it under several frameworks.
What ESG disclosure duties exist today?
On the Vietnamese side: environmental reporting, GHG inventory reporting for listed facilities, and public-company disclosure. On the group side: the parent’s disclosure calendar and templates (CSRD/ESRS or ISSB) — usually the heaviest practical duty for an FDI subsidiary.
How much does an ESG report cost?
There is no statutory fee. Costs cover data systems and reporting consultancy, the GHG inventory where mandatory, and independent assurance where required — every quotation is commercial and should be compared on a defined scope rather than a supposed “standard price”.
This article has been quality-reviewed by the FLAW AI Legal Council