For companies listed on HOSE or HNX, 2026 marks a turning point: ESG reporting is no longer a voluntary, formality-driven document, but is steadily becoming a mandatory obligation under a clear legal roadmap. This article summarizes the latest updates on ESG disclosure requirements in Vietnam, helping listed companies understand exactly where they stand in the compliance timeline and what to prepare for next.

Legal Framework: From Encouragement to Obligation

ESG disclosure obligations for listed companies in Vietnam are currently scattered across several legal documents related to securities, the environment, and corporate governance, rather than consolidated into a single unified standard. The 2019 Securities Law, together with Circular 96/2020/TT-BTC, laid the initial groundwork by requiring listed companies to publish sustainability reports or integrate ESG content into their annual reports. The 2020 Law on Environmental Protection later added an obligation to disclose environmental information under Article 137, while also introducing, for the first time, the concepts of circular economy and Extended Producer Responsibility (EPR) into the legal framework.

The most significant turning point was highlighted at the kickoff conference for the 2026 Listed Company Awards organized by HOSE: ESG reporting will shift from voluntary to mandatory under a clear rollout schedule. The phased timeline is as follows:

  • 2025: Voluntary ESG reporting applies to large listed companies within the VN30 group.

  • 2026-2027: Mandatory reporting expands to all listed companies, along with projects using preferential loan capital.

  • From 2028 onward: Requirements continue to tighten further in scope and level of detail.

In addition, under current regulations, companies with revenue exceeding VND 100 billion that are listed on the stock exchange fall under the mandatory ESG disclosure requirement, although in practice many smaller companies are also proactively preparing reports to meet market expectations.

Market Pressure Is Building Fast

Beyond the legal requirements, real pressure from capital markets and supply chains is pushing companies to act faster than the regulatory timeline itself. At the kickoff conference for the 2026 Listed Company Awards organized by HOSE, a representative from Vinamilk shared that ESG pressure is rising like never before: for export activities, EU regulations such as CBAM and CSRD are directly affecting value chains, while in capital raising, ESG has become a prerequisite that investors demand.

Data from this year's Listed Company Awards season reflects the same trend: 122 companies participated, up 27% from the previous year, with the information disclosure rate rising from 49% to 81% within a single year. This is also a period when Vietnam's market is on track to be upgraded by FTSE Russell from frontier market to emerging market status, opening the door to large-scale foreign capital inflows, while simultaneously raising expectations for transparency and standardized reporting from international investors.

The Picture Remains Uneven

Despite the overall positive trend, readiness levels vary significantly across company groups. In the financial sector, ESG has become deeply integrated into governance: many credit institutions have established dedicated Sustainable Development Committees or Sub-committees under their Boards of Directors, shifting ESG from mere commitment to actual governance mechanisms, while disclosing concrete figures on green lending and green bonds. Many organizations in this group have also adopted international standards beyond GRI, such as TCFD and ICMA.

In contrast, non-financial companies are still struggling with multiple challenges: not knowing where to start amid a maze of ESG standards, scattered data across departments, a lack of structured data collection systems, and limited internal resources. According to a VCCI survey, only about 36% of Vietnamese companies genuinely prioritize ESG, and only around 12% have independent ESG reports. Meanwhile, combined data from IFC and the State Securities Commission shows that around 80% of listed companies have disclosed some sustainability information, but most have not yet followed international standards such as GRI or SASB.

What Should Listed Companies Do Now?

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  • Identify the correct group and applicable timeline under Decree 96/2023 (VN30 or the entire exchange, the 2026-2027 phase or post-2028).

  • Review internal ESG data collection systems, especially in departments where data remains scattered without a unified consolidation process.

  • Reference relevant international standards (GRI, TCFD, SASB) rather than settling for minimum compliance with domestic law, in order to meet the expectations of foreign investors as the market approaches an upgrade.

  • Prioritize companies with EU export activities, as regulations such as CBAM and CSRD are adding an overlapping layer of disclosure requirements on top of domestic ESG reporting obligations.

  • Learn from the financial sector's experience, where establishing dedicated committees and embedding ESG into governance mechanisms has proven clearly more effective than a purely formal approach.

Vietnam's tightening ESG disclosure roadmap is unfolding alongside the market upgrade process, and listed companies that prepare early will gain a clear advantage in accessing foreign capital and maintaining relationships with international export partners.

Partner with FTK Global to build an ESG reporting roadmap aligned with each compliance milestone, ready to meet both regulatory requirements and the growing expectations of domestic and international investors.

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