Your Vietnamese customer has sent you an ESG questionnaire. Here is what the law requires of them — and what they need from you.
Vietnam has introduced mandatory sustainability reporting for listed companies through the State Securities Commission (SSC) and the Ho Chi Minh Stock Exchange (HOSE) and Hanoi Stock Exchange (HNX). Vietnam's Circular 96/2020/TT-BTC requires annual sustainability reports from listed companies. Vietnam is one of the world's fastest-growing manufacturing and export economies — a major supplier to EU, US, Japanese, and Australian markets in electronics, textiles, footwear, and furniture — and Vietnamese suppliers face ESG questionnaires from international buyers subject to CSRD, CSDDD, and California SB 253. Vietnam's EU-Vietnam Free Trade Agreement (EVFTA) further aligns Vietnamese business standards with EU ESG expectations. If you supply goods or services to a Vietnamese buyer, or if your Vietnamese buyer supplies international markets, ESG compliance evidence is increasingly a regulatory and procurement requirement.
Key regulations in Vietnam — ESG & Sustainability Reporting Supplier Guide
Circular 96/2020/TT-BTC — Mandatory Sustainability Reporting
Vietnam's Ministry of Finance issued Circular 96/2020/TT-BTC requiring all listed companies to publish annual sustainability reports. The framework is aligned with GRI Standards and requires disclosure of environmental, social, and governance performance, including supply chain sustainability. HOSE and HNX-listed companies must disclose their supplier assessment processes and supply chain sustainability data.
EU-Vietnam Free Trade Agreement (EVFTA) — Trade and Sustainability Chapter
The EU-Vietnam Free Trade Agreement includes a Trade and Sustainable Development chapter with binding commitments on labour rights (ILO conventions), environmental standards, and sustainable development. The EVFTA creates a direct link between Vietnamese export access to the EU market and compliance with international labour and environmental standards. Vietnamese exporters to the EU are expected to demonstrate compliance with these standards.
EU CSRD & CSDDD — Reach into Vietnamese Suppliers
Vietnamese companies that supply European buyers — particularly in electronics, textiles, footwear, and furniture — are subject to ESG questionnaires driven by EU CSRD and the incoming CSDDD. Vietnam is one of the EU's largest suppliers of electronics, garments, and footwear. EU fashion brands, electronics manufacturers, and furniture retailers subject to CSRD must disclose supply chain sustainability data including their Vietnamese suppliers.
California SB 253 & US Supply Chain Requirements
Vietnam is a major supplier to US markets — particularly in electronics, textiles, and furniture. US companies subject to California SB 253 must disclose Scope 3 supply chain emissions, which requires emissions data from their Vietnamese suppliers. US fashion brands and retailers are among the most active in requiring ESG compliance evidence from their Vietnamese suppliers.
SSC Circular 96 Amendment — ISSB Alignment (2025)
The State Securities Commission of Vietnam announced in November 2025 that it is amending Circular 96/2020/TT-BTC to bring sustainability reporting requirements for listed and public companies into alignment with ISSB (IFRS S1 and S2) global standards. This represents a significant upgrade from the existing GRI-based framework and will require more structured, comparable ESG disclosures from Vietnamese listed companies — including supply chain sustainability data. Vietnamese companies and their suppliers should begin preparing ISSB-aligned data now.
Germany LkSG — Supply Chain Due Diligence Act
Germany is one of Vietnam's most important trading partners. German companies subject to the Lieferkettensorgfaltspflichtengesetz (LkSG) must conduct due diligence on their Vietnamese suppliers — covering forced labour, child labour, environmental harm, and human rights violations. Vietnamese manufacturers supplying German automotive, electronics, textile, and retail buyers are actively receiving LkSG questionnaires and must be able to demonstrate compliance. Non-compliant suppliers risk removal from German supply chains.
Vietnam PDPD & VNCERT Cyber Obligations
Vietnam's Personal Data Protection Decree (Decree No. 13/2023/ND-CP) requires data controllers to notify the Ministry of Public Security's Department of Cybersecurity and Hi-Tech Crime Prevention within 72 hours of becoming aware of a personal data breach. Vietnam's VNCERT/CC (Vietnam Computer Emergency Response Team / Coordination Centre) coordinates national cyber incident response under the Ministry of Information and Communications. The Cybersecurity Law (2018) mandates cybersecurity controls for critical information infrastructure operators. Suppliers processing Vietnamese customer data must align incident response to the 72-hour notification window.
What this means for you as a supplier
You may not be directly regulated by all of these frameworks. But your Vietnamese buyer is — and so are the international buyers in your supply chain. HOSE/HNX-listed companies must disclose supply chain sustainability data. EU buyers must assess Vietnamese suppliers under CSRD and CSDDD. The EVFTA creates direct obligations on Vietnamese exporters to the EU market. A non-response or a weak response increases your buyer's regulatory risk and makes you a liability in their supply chain.
Key dates
August 2020
EVFTA enters into force — binding labour rights and environmental standards for Vietnamese exporters to the EU
2020 onwards
Circular 96/2020/TT-BTC — mandatory sustainability reporting for all listed companies
Active now
EU CSRD — large EU companies must disclose supply chain sustainability data including Vietnamese suppliers
2026
California SB 253 mandatory Scope 3 reporting — US buyers must disclose supply chain emissions including Vietnamese suppliers
July 2029
EU CSDDD Phase 1 — large EU companies must conduct active supply chain due diligence; Vietnamese suppliers will receive structured questionnaires
Vietnam's EVFTA obligations and growing ESG framework
Vietnam's EU Free Trade Agreement includes binding commitments on labour rights and environmental standards — a direct link between export market access and ESG compliance. Vietnamese exporters to the EU are expected to demonstrate compliance with ILO conventions and environmental standards as a condition of preferential trade access. Combined with Vietnam's own mandatory sustainability reporting framework under Circular 96/2020, Vietnamese companies face ESG obligations from both domestic regulation and international trade agreements.
Electronics, textiles, and footwear — EU and US supply chain pressure
Vietnam is one of the world's largest exporters of electronics, garments, footwear, and furniture. EU fashion brands, electronics manufacturers, and furniture retailers subject to CSRD must disclose supply chain sustainability data including their Vietnamese suppliers. US fashion brands and retailers are among the most active in requiring ESG compliance evidence from their Vietnamese suppliers. Vietnamese suppliers in these sectors who can provide structured ESG evidence are significantly better positioned to maintain and grow their international market share.
What your Vietnamese buyer's questionnaire will ask
Environmental management
Environmental management systems, waste management, water usage, and compliance with Vietnamese environmental law. EU buyers require evidence of environmental compliance. Textile and electronics manufacturers face specific chemical and waste management requirements.
GHG emissions and climate data
Scope 1 and Scope 2 emissions data, and increasingly Scope 3 (supply chain) emissions. HOSE/HNX-listed companies and EU CSRD buyers require supply chain emissions data. Vietnam has a net-zero target of 2050.
Labour rights and working conditions
Compliance with Vietnamese Labour Code, minimum wage, working hours, health and safety, and freedom of association. The EVFTA requires compliance with ILO conventions. EU and US buyers will reference CSDDD and their own supply chain due diligence laws.
Human rights due diligence
A written policy covering forced labour, child labour, and non-discrimination. Evidence that you assess your own supply chain for human rights risks. EU CSDDD and the EVFTA both require documented human rights due diligence.
Supply chain traceability
Evidence of your own supplier assessment processes. EU and US buyers require traceability through the supply chain. Textile and electronics suppliers face specific material traceability requirements.
Governance and anti-corruption
Anti-bribery and anti-corruption policies aligned with Vietnamese law. Board oversight of ESG matters. International buyers will reference their own jurisdiction's anti-corruption laws and the UN Global Compact.
What happens if your response is inadequate
- →Your HOSE/HNX-listed buyer must disclose supply chain sustainability data — a non-response creates a gap in their mandatory sustainability report
- →EVFTA obligations mean EU buyers can raise concerns about Vietnamese suppliers' labour and environmental compliance — weak responses create trade access risk
- →EU fashion brands and electronics manufacturers subject to CSRD need your supply chain data to complete their own mandatory disclosure
- →EU buyers subject to CSDDD may be required to source from suppliers who can demonstrate compliance — a non-response puts your contract at risk from July 2029
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
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