Independent assurance of GHG inventories and ESG data: who is actually required to buy it, from when, and how the cost is built

Quick answer: most small and medium enterprises in Vietnam are not yet legally required to hire a third party to verify their greenhouse gas inventory. The mandatory duty falls on facilities allocated emission quotas: under Article 11 of Decree 06/2022/ND-CP as amended by Decree No. 119/2025/ND-CP of 9 June 2025, verification of those facilities' inventory results is performed by the unit specified in Article 14 of this Decree, and the facility must file with the Ministry of Agriculture and Environment an inventory report that has been verified, before 1 December, from 2027 onwards (signed Official Gazette PDF, page 7). For every other business the real pressure comes from customers, banks and the EU's CBAM — not from the domestic regulator.

Last updated: 4 September 2026.

The short version

Eight points if you only have three minutes, each with a date and a checkable source:

• Three different activities share one name: the state reviews and consolidates; an Article 14 unit verifies (mandatory, for a defined group); an international assurance provider issues assurance under a commercial contract with you.
• The law in force: Decree 06/2022/ND-CP of 7 January 2022, amended by Decree 119/2025/ND-CP (effective 1 August 2025) and Decree 83/2026/ND-CP (effective 23 March 2026).
• Decree 83/2026 does not touch verification — we read the full text: it only amends Articles 24 and 26 and replaces several forms in Appendix VI, all concerning controlled substances.
• The binding date is 2027, not today: quota-allocated facilities file the verified inventory report with the Ministry before 1 December, from 2027 onwards.
• Quota-allocated facilities in 2025-2026 are thermal power plants, iron and steel producers and cement producers on the Prime Minister's list — very few SMEs sit there.
• The definition of a verification unit is narrow: an organisation holding a certificate of registration for validation and verification activity under the law on conditions for conformity assessment services. Not every consultancy qualifies.
• The international market is far ahead: 73 per cent of large G20 companies obtained assurance over at least part of their 2023 sustainability disclosures, and most of it is still limited in scope.
• The right first move is not to request verification quotes but to build an evidence trail any third party can follow back to source. Without it, every quote prices work of unknown size.

Key facts — one date, one authority and one checkable source per line:

• 9 June 2025, effective 1 August 2025: Decree No. 119/2025/ND-CP amending Decree 06/2022/ND-CP, signed by Tran Hong Ha, per the document record on the Government legal documents portal.
• Full text of amended Article 14: the verification unit for greenhouse gas inventory results and emission reduction is an organisation granted a certificate of registration for validation and verification activity under the law on conditions for conformity assessment service businesses — signed Official Gazette PDF, page 9.
• 23 March 2026: Decree No. 83/2026/ND-CP issued and effective the same day, further amending Decree 06/2022 — but only in the procedural provisions on controlled substances, per its document record and its full Gazette text.
• 12 May 2025: IFAC with AICPA & CIMA published the five-year update of The State of Play: Sustainability Disclosure and Assurance, covering 1,400 companies across 22 jurisdictions — "Seventy-three percent of large companies from G20 countries obtained assurance on their sustainability disclosures in 2023, up from 69 percent the previous year", per the IFAC announcement.
• 12 November 2024: the IAASB issued ISSA 5000, described as "profession agnostic, supporting its use by both professional accountant and non-accountant assurance practitioners".
• 1 January 2026: the EU's CBAM entered its definitive regime; where actual emissions are declared, "the verification must be carried out by independent verifiers accredited by EU national accreditation bodies", and the first CBAM verifiers "are expected to receive CBAM accreditation around September 2026" — European Commission, Verification of CBAM emissions.

Scope note: this article describes rules in force and publicly released data. It is not legal advice, it is not a determination of whether your company falls inside a mandatory category, and it contains no market price — because we could not find a verifiable public source for verification fees in Vietnam. Every environmental statement here is tied to a specific figure or a specific provision; where something is GROW's own assessment, we label it as such.

Verification, validation, assurance: three different jobs under one name

Direct answer: in Vietnamese commercial usage today, three very different activities are all called "tham dinh" — and buying the wrong one means paying for a deliverable nobody will accept. Telling them apart is step one, before you ask about price.

The first is administrative review by the state. Under Article 11 of Decree 06/2022/ND-CP as amended, a listed facility runs its own inventory, prepares the report on Form 06 of Appendix II and sends it to the provincial People's Committee before 31 March. The province then receives, reviews and consolidates the inventory results of facilities in its area and forwards them to the Ministry of Agriculture and Environment and the line ministries before 30 June. This is an administrative procedure that costs the company nothing, and it is not an assurance opinion on the reliability of your data. Put plainly: the province receiving your report does not mean anyone has checked your numbers.

The second is mandatory verification under Article 14. This is the activity performed by an outside organisation that you pay for. The amended Article 14 defines it narrowly: the verification unit is an organisation granted a certificate of registration for validation and verification activity under the law on conditions for conformity assessment service businesses. The two Vietnamese phrases in that sentence are the statutory rendering of what English calls validation and verification. The point to remember is that the qualifying condition is an operating licence, not a training certificate or a claim of competence.

The third is assurance under international standards. This is what foreign customers, development banks and investors tend to ask for, and it sits outside Vietnamese law. Until recently the common standard was ISAE 3000 (Revised); since 12 November 2024 the IAASB has issued ISSA 5000 as a single standard for sustainability assurance engagements, which the board says "will apply to sustainability information reported across any sustainability topic and prepared under multiple frameworks". The key difference from the second activity: international assurance is a commercial contract between you and the provider, and the deliverable is an assurance report addressed to readers you nominate, not a filing to a government body.

Why be this pedantic? Because the three differ in who reads the output. If the reader is the provincial People's Committee, you need the right form on time. If the reader is the Ministry within a quota file, you need an Article 14 unit. If the reader is a European group's procurement team, they will ask which standard and which level of assurance — and "we filed it with the province" will not count. We covered the data and boundary work of the inventory itself in our piece on Scope 1-2-3 greenhouse gas inventories for SMEs; this article starts where that one ends.

Table 1 — Three jobs sharing one name. Sources for columns two and three: the full text of Articles 11 and 14 of Decree 06/2022/ND-CP as amended by Decree 119/2025/ND-CP, read directly from the Official Gazette PDF. International assurance column: the IAASB's ISSA 5000 page. The "who pays" row describes practice, not a rule.

Criterion	State review	Article 14 verification	International assurance
Who does it	Provincial People's Committee and line ministries	An organisation holding a certificate of registration for validation and verification activity	An audit firm or a specialist assurance provider
Legal basis or standard	Article 11, amended Decree 06/2022	Article 11(6a) and Article 14, amended Decree 06/2022	ISSA 5000 (IAASB, 12 Nov 2024); previously ISAE 3000 (Revised)
Mandatory for whom	Every facility on the inventory list	Facilities allocated emission quotas	Nobody — unless a contract, a shareholder or an importing country's law requires it
Does the company pay?	No	Yes	Yes
Deliverable	Results consolidated up to ministry level	A verified inventory report for filing with the Ministry	An assurance report addressed to readers the company nominates
Deadline	Facility to province by 31 Mar; province to ministry by 30 Jun	File with the Ministry by 1 Dec, from 2027	The company's own reporting calendar or the customer's demand

Who Vietnamese law actually obliges, and from when

Direct answer: the duty to hire a verification unit attaches to whether you are allocated an emission quota, and the first filing deadline for a verified report is 1 December, from 2027 onwards. If your company is merely on the inventory list without a quota, you file with the province and stop there.

We downloaded the digitally signed Official Gazette PDF of Decree 119/2025/ND-CP from the Government document store. It is a scanned file with no text layer — extraction tools return zero characters — so we extracted the page images and read them by eye rather than relying on online summaries. The three provisions below sit on pages 7 and 9 of that file.

Article 11(4)(b) as amended sets the baseline duty for every listed facility: run the facility-level inventory, prepare the report every two years from 2024 onwards on Form 06 of Appendix II and send it to the provincial People's Committee before 31 March, from 2025. In the same article, a new point (e) in clause 1 adds a technical detail that is easy to miss: the biennial report covers the inventory results of the two years immediately preceding the year of filing. In other words you still need annual data; you merely file it two years at a time. A company that reads this as "we only have to measure every second year" will lose the middle year entirely and will not be able to reconstruct it.

Article 11(4)(c) and (d) carve out the group that will receive quotas: thermal power plants, iron and steel producers and cement producers on the Prime Minister's list prepare biennial inventory reports from 2026 onwards; facilities outside that group but allocated quotas from 2027 prepare biennial reports from 2028 onwards. Amended Article 12 confirms the same picture: in the 2025-2026 period, the quota-allocated facilities are exactly those three industries.

Article 11(6a) as amended is the decisive sentence for this whole article: verification of the inventory results of facilities allocated quotas under points (c) and (d) of clause 4 is performed by the unit specified in Article 14 of this Decree, and the quota-allocated facility sends the Ministry of Agriculture and Environment the verified greenhouse gas inventory report before 1 December, from 2027. Read slowly, that sentence says three things: the duty applies only to quota holders; the verifier must be an Article 14 unit; and the first deadline is 2027, not now.

One more point, so nobody concludes the state has handed the job to the private sector and walked away: amended Article 15(1) makes the Ministry of Agriculture and Environment responsible for inspecting and supervising verification activity for greenhouse gas inventory results and emission reduction. And amended Article 9(6) places the duty to comply with measurement, reporting and verification rules on both the facility and the verification unit specified in Article 14. A verification unit is a supervised entity, not a free-roaming consultant.

What about Decree 83/2026/ND-CP? Because its full title reads "amending and supplementing a number of articles of Decree No. 06/2022/ND-CP", it is easy to assume the inventory and verification duties have changed. We downloaded the full .docx from the Official Gazette and read it: the decree has five articles, of which Article 1 amends clauses of Article 24, Article 2 amends clauses of Article 26, and Article 3 replaces several forms in Appendix VI — all within the registration and quota allocation regime for controlled substances under the Montreal Protocol, that is, the ozone side. The Vietnamese word for verification appears zero times in the full text. Conclusion: the verification regime stands exactly as Decree 119/2025 left it.

If you are not sure whether your facility is on the inventory list at all, that is the question to answer first, and it lives in a separate Prime Ministerial decision rather than in the decree. We wrote separately about the emissions-data duties that follow exporters in our piece on CBAM compliance for SME exporters, and our article on ESG reporting under GRI and ISSB explains the disclosure frameworks sitting behind the numbers.

Table 2 — Vietnamese legal milestones on greenhouse gas inventory verification, as at 4 September 2026. Sources: document records on the Government legal documents portal and the full Official Gazette text of each decree, read directly. Only provisions bearing on a company's measurement, reporting and verification duties are listed.

Instrument	Issued	Effective	Relevant content
Decree 06/2022/ND-CP	7 Jan 2022	—	Base regime: greenhouse gas mitigation and ozone layer protection
Decree 119/2025/ND-CP	9 Jun 2025	1 Aug 2025	Amends Article 11 (facility inventory; adds clause 6a on verification), Article 12 (quota allocation), Article 14 (definition of a verification unit), Article 15 (supervision of verification)
Decree 83/2026/ND-CP	23 Mar 2026	23 Mar 2026	Amends only Articles 24 and 26 and several Appendix VI forms on controlled substances — contains no verification provision

Table 3 — Who must do what, under Article 11 of Decree 06/2022/ND-CP as amended. Source: the full Official Gazette PDF of Decree 119/2025/ND-CP, page 7, read from page images because the scan has no text layer. The final column is GROW's practical reading, not the wording of the decree.

Facility group	Inventory reporting cycle	Filed with whom, by when	Must hire a verification unit?	Practical consequence (GROW assessment)
Listed facility, no quota allocated	Every two years, from 2024	Provincial People's Committee, before 31 Mar	No	Zero third-party cost as a matter of law; any pressure comes from customers
Thermal power, iron and steel, cement on the list	Every two years, from 2026	Province before 31 Mar; verified report to the Ministry before 1 Dec from 2027	Yes	Select and contract the Article 14 unit ahead of the reporting cycle, not close to the deadline
Other facilities allocated quotas from 2027	Every two years, from 2028	As above	Yes	If your sector may enter the 2027-2028 quota list, prepare the file from the 2026 data year

The three sources of demand an SME actually meets

Direct answer: for most Vietnamese SMEs in 2026 the strongest source of demand is not domestic law but the contract with a foreign customer and the EU's CBAM. The three differ in the level of assurance required, in who is allowed to perform it, and in what happens if you have none.

Source one — domestic law. As above, the duty applies to quota holders, the deadline is 1 December from 2027, and the performer must be an Article 14 unit. Failure is administrative: an incomplete quota file. For a metalworking shop or a 300-worker garment plant the chance of landing in that group within two years is low — but low is not zero, because the inventory list is updated periodically and thresholds can fall.

Source two — the EU's CBAM. This is the most concrete and the most demanding. The European Commission states that the definitive CBAM regime "applies from 1 January 2026", and that where an importer declares actual rather than default emissions, "the verification must be carried out by independent verifiers accredited by EU national accreditation bodies". Two details on the same page are routinely missed by Vietnamese suppliers. First: "CBAM verification applies at the level of the installation where CBAM goods are produced" — meaning your plant in Vietnam is the object of verification, not the importer's office in Europe. Second: CBAM verifiers "provide reasonable assurance that the calculation of embedded emissions is correct" — that is the higher level of assurance, not the limited level common in sustainability reporting.

One timely detail for anyone planning ahead: the same page notes that the first CBAM verifiers "are expected to receive CBAM accreditation around September 2026". In other words, as this article is updated, the CBAM verifier pool is only just forming. Practical consequences: if your EU customer intends to use actual emissions, do not assume a verifier will be free at short notice; and conversely, be sceptical of any provider claiming to have been a CBAM verifier for years without producing evidence of accreditation from an EU national accreditation body.

Source three — customers, banks and investors. Legally the softest, commercially the hardest, because it is attached to orders. The transmission mechanism is simple: the company at the top of the chain must disclose Scope 3, and their Scope 3 is your Scope 1 and Scope 2. The IFAC data shows that pressure is real: among companies disclosing emissions, assurance now covers Scope 3 for "76% of those that disclosed Scope 3 emissions—an increase over 60% in 2022". When the buyer is paying to assure a number whose raw input is your data, they will demand that data in a traceable form — and that is the point at which scattered spreadsheets stop being enough.

A legal caution we repeat in every engagement: holding an assurance report does not entitle you to claim a "green factory" or a "carbon-neutral product". An assurance report says that a defined data set, within a defined boundary, is free from material misstatement against stated criteria. It does not say your business is good for the environment. Sliding from the first to the second in marketing copy is the hardest form of greenwashing to defend, precisely because you have handed the reader a technical document to check you against. We set out that boundary in our article on green labels and anti-greenwashing for SMEs.

Table 4 — Three sources of verification demand, compared on four decisive criteria. Sources: for Vietnamese law, the full text of amended Decree 06/2022/ND-CP; for CBAM, the European Commission's Verification of CBAM emissions and CBAM definitive regime pages; for customers, the IFAC and AICPA & CIMA State of Play study published 12 May 2025. The "consequence" row is GROW's assessment.

Criterion	Vietnamese law	CBAM (EU)	Customers, banks, investors
Who is caught	Facilities allocated emission quotas	Installations producing CBAM goods declared on actual emissions	Suppliers to companies that must disclose Scope 3
Timing	Verified report filed before 1 Dec, from 2027	Definitive regime from 1 Jan 2026; first verifiers expected accredited around Sep 2026	The buyer's contract and reporting cycle
Level of assurance required	The decree uses "verification" without mapping to international levels	Reasonable assurance	Usually limited assurance; some large buyers demand more for emissions data alone
Who may perform it	A unit holding the Article 14 registration certificate	Verifiers accredited for CBAM by an EU national accreditation body	Whoever the buyer accepts; in practice audit firms or international assurance providers
Consequence of having none (GROW assessment)	Incomplete quota file	Declaration falls back to default values, usually worse than actual	Removal from the approved supplier list, or a higher risk price

Limited and reasonable assurance: what separates them, and what the market buys

Direct answer: limited assurance takes less work and concludes more weakly; reasonable assurance takes more work and concludes more strongly — and as at the 2023 data year the global market still mostly buys the first. Knowing which one you are buying is the minimum condition for not paying for the wrong thing.

The difference lies in how much evidence the provider must gather and in how the conclusion is worded. Limited assurance ends in a negative form: the practitioner states that nothing has come to their attention to suggest the information is materially misstated. Reasonable assurance ends in a positive opinion: in their view the information is prepared, in all material respects, in accordance with the stated criteria. That one-word difference drives large differences in person-days, in the number of documents sampled, and in how much the provider must measure for themselves rather than simply interview.

Where is the market? The five-year study by IFAC with AICPA & CIMA, built on the practice of 1,400 companies across 22 jurisdictions, gives a clear picture. Disclosure is effectively saturated: "The percentage of companies engaged in sustainability reporting remained unchanged at 98%". Assurance is climbing steadily: 51 per cent in 2019, 69 per cent in 2022, 73 per cent for 2023. But immediately after that number, the IFAC announcement adds a line that vendors rarely quote: "Most of the assurance then and now is of limited scope."

Two further data points inside the report help you place yourself. First, when companies start buying assurance, they buy it for emissions data first: the report finds that among assured topical disclosures, "most focus on greenhouse gas emissions data (99%)". Second, when they step up to reasonable assurance, they step up for the emissions part rather than the whole report: "Nearly two-thirds of reasonable assurance only covered GHG metrics", while "Nearly 70% of limited assurance covered social and governance metrics". For a Vietnamese supplier the implication is blunt: spend on the quality of your emissions data first, the social and governance material second.

On providers, the same study reports that audit firms still lead but are losing share: they "continue to lead (55 percent) in providing assurance on sustainability disclosures by large global companies", down from 58 per cent in 2022. Standards use splits by provider type: 92 per cent of firms applied ISAE 3000 (Revised), while among other service providers only 38 per cent did. That is precisely the gap ISSA 5000 was designed to close — the IAASB built it to be profession agnostic, usable by accountant and non-accountant practitioners alike.

One technical caution to avoid an expensive mistake: the data you put into an assurance engagement must be prepared against a named set of criteria. For corporate emissions the most common is the GHG Protocol Corporate Standard, which its own page describes as a document that "provides requirements and guidance for companies and other organizations preparing a corporate-level GHG emissions inventory". The same page flags a boundary that is often crossed: the standard "should not be used to quantify the reductions associated with GHG mitigation projects for use as offsets or credits". Meaning a corporate inventory is not a basis for generating carbon credits, and anyone selling you a bundle of "inventory now, sell credits next" is mixing two different jobs.

Table 5 — Global sustainability assurance practice, 2023 data year. Source: IFAC and AICPA & CIMA, "The State of Play: Sustainability Disclosure and Assurance — Five-Year Trends and Analysis (2019-2023)", published 12 May 2025, sample of 1,400 companies across 22 jurisdictions. This describes large G20 companies; it cannot be read across directly to Vietnamese SMEs.

Indicator	Value	Note
Companies disclosing sustainability information	98%	Unchanged on the prior year
Companies with assurance over at least part of it	73%	69% in 2022; 51% in 2019
Nature of that assurance	mostly limited scope	Verbatim: "Most of the assurance then and now is of limited scope."
Audit firms' share of assurance engagements	55%	Down from 58% in 2022
Topical focus of assured disclosures	greenhouse gas emissions data, 99%	Companies report far more widely than they assure
Reasonable assurance covering only GHG metrics	nearly two-thirds	The higher level is reserved for the arithmetic
Limited assurance covering social and governance metrics	nearly 70%	Qualitative material tends to stop at the lower level
Scope 3 disclosers who also assured that data	76%	Up from 60% in 2022 — this is how the pressure reaches suppliers
Use of ISAE 3000 (Revised)	audit firms 92% · other providers 38%	The gap ISSA 5000 aims to close

How the cost is built — no market price here, only the formula

Direct answer: the fee for a verification or assurance engagement is person-days times a day rate, plus travel; and the variable that drives person-days is the quality of your evidence, not the size of your revenue. Most of the saving therefore sits on your side of the table, not in the negotiation.

We deliberately publish no monetary figure. The reason is specific: while sourcing this article we could not find a single verifiable public source publishing a fee range for greenhouse gas inventory verification in Vietnam. The numbers circulating online all sit on the sales pages of the providers themselves, with no sampling method and no cut-off date. Putting them into a cited article would convert a sales pitch into a market fact, which is exactly the failure this article criticises. So instead of inventing a range, we give the formula.

The cost has four components. The largest is the team's person-days: planning, time on site, desk testing of evidence, and independent technical review inside the provider's own quality system. The second is travel and accommodation, which scales with the number of locations — a company with three plants in three provinces costs materially more than a company with one plant, even at identical total emissions. The third is the cost of resolving findings: every time the team hits something that cannot be traced and has to come back, that is additional person-days. The fourth is the provider's system maintenance cost, which you never see itemised but which sits inside the day rate.

The single biggest inflator is data that cannot be traced. A very ordinary example: you report a total volume of diesel burnt in the standby generator for the year. The team will ask where that number came from. If the answer is "accounting added up the invoices", they will ask for the invoices and reconcile them against the generator's run log. If there is no run log, or there is one and it disagrees, they cannot conclude and must widen the sample. Every widening is more person-days. The same logic applies to purchased electricity, to refrigerant top-ups, to forklift usage in the warehouse.

What lowers the cost is remarkably mundane: one data ledger instead of seven spreadsheets on seven laptops; a pointer from every reported figure to a source document; one named person accountable for answering queries; and an emission-factor set that records source, version and lookup date for each factor. None of these costs money to buy; they cost discipline. We described how to build that data set in our piece on Scope 1-2-3 greenhouse gas inventories, and it is exactly the work GROW does for clients.

One rule when reading quotes: compare on scope, not on the total. Two quotes that differ by a factor of two may simply reflect one covering site visits to all three plants while the other visits one and extrapolates. Four questions to ask before comparing money: which emission sources are in scope; what level of assurance; how many site days and how many locations; and how additional testing is charged if discrepancies are found.

Table 6 — Cost components of a verification or assurance engagement, and who controls each variable. This is GROW's analytical framework based on the work structure of an assurance engagement. It is not a price list and cites no price source — we could not find a verifiable public source for these fees in Vietnam.

Component	Driving variable	Who controls it	How to bring it down
Planning person-days	Complexity of organisational and operational boundaries	The company	Settle the legal-entity map and site list before inviting quotes
On-site person-days	Number of sites and sources needing direct observation	Shared	Have documents ready on site; send someone who actually runs the equipment with the team
Desk testing person-days	Share of reported figures with a pointer to a source document	The company	Build a single-source data ledger and index documents line by line
Findings person-days	Number of untraceable points and sample widenings	The company	Run your own internal dry run before inviting anyone in
Travel and accommodation	Number of provinces, distance	Not changeable	Batch multi-site visits into one trip
Day rate	Assurance level, sector competence, provider standing	The provider	Step up to reasonable assurance only for the data that genuinely needs it

What has to be ready before a verifier walks into your plant

Direct answer: if you cannot trace a figure in the report back to a dated source document, you are not ready to invite anyone in. This is the number one reason engagements overrun on both cost and schedule.

First file — boundaries. Three questions come before all others: which legal entities are in the reporting scope; which sites are in scope; and for each site, do you have operational control or merely lease part of the floor area. A workshop leased inside an industrial park whose electricity runs through a shared building meter is extremely common in Vietnam, and if you have not resolved the allocation method the team will stop right there.

Second file — activity data. For each emission source you need three things together: the figure for the reporting period, the source document proving it, and a description of how you derived it. Electricity means monthly utility invoices. Fuel means purchase invoices plus issue logs and opening and closing stock. Refrigerant means maintenance records showing top-up quantities. If some source is estimated rather than measured, say so and state the method — concealing it is the fastest way to lose the team's confidence in everything else.

Third file — factors and arithmetic. Every emission factor needs its issuing source, its version or applicable year, and the date you looked it up. Spreadsheets must keep formulas live rather than pasted values. This is the difference between a file verified in three days and one that takes three weeks: the team must be able to recompute your result from raw data without asking anyone.

Fourth file — internal control. Who enters the number, who checks it, who approves it, and what evidence shows the check actually happened. In an SME those three roles often sit with one or two people, and that is not wrong — but say so plainly rather than drawing an org chart that does not exist, because the team will test it by cross-questioning individuals.

Fifth file — the trail of restatements. Almost every company restates something during a period. What the team wants to see is not a flawless first draft but a record of what changed, why, and who approved it. A data set with no correction history at all tends to make an experienced reviewer more suspicious, not less.

What GROW does, what it will not do, and your next 90 days

Direct answer: GROW builds the data and the file so that your company is ready to be verified — and precisely for that reason GROW does not take the role of verifying the file it built. That boundary is not modesty; it is the condition on which your file has value to an outside reader.

The reason sits in the nature of independent assurance: an opinion is only worth something if the person giving it is not the person who produced the thing being checked. In the Vietnamese system, Article 14 sets a registration certificate for the right category of service as the qualifying condition, and Article 15 puts the Ministry of Agriculture and Environment in the supervisory role over verification activity. In the international system, assurance standards place independence and objectivity on the practitioner. Both roads lead to the same practical conclusion: the firm that built your numbers does not sign off on them.

What GROW does is the work before and after. Before: set organisational and operational boundaries, build a single-source data ledger, standardise source documents, select and document emission factors, and run an internal dry run that mirrors how a verification team will actually question you. After: translate the result into something customers and banks can read, and review every environmental claim in your sales material so that no sentence outruns the evidence behind it. What GROW does not do: issue an Article 14 verification report, issue an assurance report under international standards, or verify emissions for a CBAM file. Those belong to organisations accredited for exactly those activities, and we will say so plainly when your situation calls for them.

Task one in the next 90 days — establish where you stand. Answer two questions: is your facility on the Prime Minister's greenhouse gas inventory list, and are you in the group allocated emission quotas. The first decides whether you owe the province a report before 31 March. The second decides whether you must hire a verification unit before the 1 December 2027 deadline. Only if both answers are yes is requesting verification quotes the right move today.

Task two — ask your largest customer one very specific question. Namely: "Over the next two years, will you require supplier emissions data to be assured by a third party, and if so at what level of assurance?" The answer will shape your budget more than any decree. If that customer exports CBAM goods into the EU, ask further whether they intend to declare actual emissions or default values — only the former triggers verification at your own plant.

Task three — run your own dry run before inviting anyone in. Pick five figures at random from your most recent inventory report and try to trace each one back to a source document, timing yourself. If any single line takes more than thirty minutes, you now know where your verification cost will sit and what to fix first. It is the cheapest and most honest test a company can run on itself.

If you would like someone alongside you for those three tasks, GROW's green transition advisory team can review your existing file and identify the points that will break under a verification team, before you sign anything. You can contact GROW to arrange it. We do not sell verification services, we do not represent any verification body, and we take no referral fee — stated plainly so you know which side of the table we sit on.

The closing point: under Vietnamese law as it stands, only facilities allocated emission quotas must file a greenhouse gas inventory report verified by an Article 14 unit, and the first deadline is 1 December 2027 — so for most small and medium enterprises the right question in 2026 is not "who should verify us" but "can anyone at all trace every figure in my file back to its source document".