Forest carbon credits under Decree 180/2026: which SMEs can buy, who can sell, and how to trade legally

Quick answer: Decree 180/2026/NĐ-CP (signed 21 May 2026, effective 15 July 2026) creates Vietnam's first legal framework for the forest carbon market. For a small and medium enterprise (SME), the key is not to conflate three different things: the right to offset against a quota using forest carbon credits applies only to facilities that have been allocated an emissions quota; buying credits voluntarily for ESG purposes is allowed but must go through a contract or an exchange and be confirmed by the Ministry of Agriculture and Environment; and if you are an SME that owns forest, you may instead be a seller. In every case: buying credits is not net-zero.

Last updated: 07/08/2026.

A quick summary for busy readers

Six points to remember, each with an official source in the article:

• This is a first legal framework, not an optional guideline. Decree 180/2026 comprehensively governs the supply, confirmation, trading and benefit-sharing of forest carbon credits.
• Informal trades are over. All transactions must go through a contract or a carbon exchange, and be confirmed by the Ministry of Agriculture and Environment before transfer.
• No double selling. Once transferred by contract or on an exchange, credits cannot be resold to a third party.
• Quota offsetting is a right of ETS facilities, not of every SME. Only emission sources allocated a quota may use forest carbon services to offset above-quota emissions.
• Forest-owning SMEs can be sellers. Forest owners, including households and communities, may join forest carbon projects and share the benefits.
• Credits do not replace cuts. For ESG reporting and anti-greenwashing, the order is still measure first, cut first, offset last.

Key facts — one verifiable source per line:

• Decree 180/2026/NĐ-CP on forest carbon sequestration and storage services was issued on 21 May 2026 and takes effect on 15 July 2026, comprising four chapters, 20 articles and six appendices (Vietnam News / VNA, 3 July 2026).
• Services may be carried out through contracts or via a carbon trading exchange, and payments may be made directly or through the Viet Nam Forest Protection and Development Fund (Nhan Dan Online, 25 May 2026).
• The activities must not affect Vietnam's international greenhouse gas emission reduction commitments (Nhan Dan Online).
• Revenue from forest-based carbon credits will be prioritised for forest protection and development and community livelihoods (Eco-Business, 2026).
• Payment levels are calculated in Vietnamese dong per tonne of CO₂, per tonne of CO₂ equivalent, or per forest carbon credit (Nhan Dan Online).
• Vietnam's outstanding green credit reached nearly VND 828 trillion cumulatively by the end of Q1 2026 (31 March 2026), across 82 credit institutions — State Bank of Vietnam data announced on 9 June 2026 (Nong nghiep & Moi truong, 9 June 2026).

What Decree 180/2026 does, and why it matters

Direct answer: Decree 180/2026 is the first document to comprehensively regulate developing, confirming, trading and benefiting from forest carbon credits in Vietnam. Before it, "selling forest carbon" was talked about widely but had no clear legal channel.

According to Vietnam News, the decree "creates a comprehensive legal basis for forest carbon services and provides a clear framework for generating, managing and trading forest carbon credits", and comprises four chapters, 20 articles and six appendices covering project documentation, methods for allocating emissions reduction targets, contract templates and financial management (Vietnam News, 3 July 2026). A foundational principle: these activities "must not affect the international commitments on greenhouse gas emission reductions to which Viet Nam is a party" (Nhan Dan Online, 25 May 2026). In other words, forest carbon credits are not an unlimited free-flowing commodity: part of the emission reductions is reserved for Vietnam's Nationally Determined Contribution (NDC) — which is why there is an export cap.

Why should an SME care about a decree that looks "for the forestry sector"? Because more and more SMEs are asked to prove emission cuts by EU customers, banks and supply chains — and "buy forest carbon to offset" is the most heavily marketed, and most misunderstood, answer. Decree 180 is the first text to state clearly who may buy, how, and where it counts. We mapped the domestic carbon market in Vietnam's carbon market for SMEs; here we focus on forest carbon credits under Decree 180.

Two SME roles: supplier or user of the service

Direct answer: before asking "can an SME buy forest carbon credits", identify your role. Decree 180 clearly separates two sides — the service supplier and the service user — with very different conditions.

The supplier is a forest owner or their representative: they build and register a forest carbon project, organise measurement, reporting and verification, receive credits and sell. Notably for rural areas, the decree lets households, individuals and communities that are forest owners join forest carbon projects under domestic or international standards. For publicly-owned forests, the Ministry of Agriculture and Environment or provincial People's Committees represent ownership depending on who manages the project (Vietnam News).

The user is an organisation that buys emission reductions or forest carbon credits. The core condition: it must operate lawfully under Vietnamese investment and enterprise law, perform the contract or comply with carbon exchange rules, and meet its financial obligations. A lawful SME can be a user — but "may buy" and "may offset against a quota" are two different things, separated in the two sections below.

Table 1 — The two roles under Decree 180/2026 and their conditions.

Criterion	SUPPLIER (seller)	USER (buyer)
Who qualifies	Forest owners under the Forestry Law; households, individuals, communities; provincial authorities / MAE (public forests)	Organisations operating lawfully under Vietnamese investment and enterprise law (domestic or foreign entities lawfully active in Vietnam)
What they must do	Build and register a project; measure, report, verify; obtain credits; contribute reductions + financial obligations	Sign a contract or trade on an exchange; perform the contract; meet tax/fee obligations if any
Typical SME	Agri-forestry SMEs, forestry cooperatives, production forest owners	SMEs with ESG/net-zero commitments buying voluntary credits
Opportunity / risk	New revenue from forests; risk is measurement–verification cost and methodology	A transparent offset tool; risk is buying informal credits or misusing them in reports

SMEs buying voluntarily: allowed, but on four conditions

Direct answer: a lawful SME may buy forest carbon credits voluntarily to serve its own ESG goals. But a trade is valid only if it meets four conditions — and buying cheap "off the books" is no longer an option.

Four conditions from the decree's principles: (1) the trade must go through a commercial contract or a carbon exchange, not informal deals; (2) transfer is allowed only after the Ministry of Agriculture and Environment confirms the reduction/credit volume; (3) transferred credits cannot be resold to a third party — the anti-double-selling rule; (4) payment is made directly to the supplier or entrusted through the Forest Protection and Development Fund, calculated in VND per tonne of CO₂ equivalent or per credit (Nhan Dan Online, 25 May 2026).

For SMEs this is actually good news: it protects you from buying credits already sold to someone else. The anti-double-selling mechanism is precisely what gives the credits you buy their value when they enter a report.

Table 2 — Before and after Decree 180: how to buy forest carbon credits legally.

Aspect	"Hand-to-hand" (no longer valid)	Under Decree 180 (valid)
Trade form	Verbal deals, off-the-books trading	Commercial contract or carbon exchange
Legal confirmation	Not required	Must be confirmed by MAE before transfer
Anti-double-selling	Uncontrolled — one credit sold many times	Once transferred, cannot be resold to third parties
Value in ESG reporting	High risk, hard to prove origin	Traceable, more credible to auditors

Quota offsetting: a right of ETS facilities, not a default for SMEs

Direct answer: this is where SMEs most often go wrong. Using forest carbon credits to "offset above-quota emissions" applies only to facilities allocated an emissions quota — the large facilities in the emissions trading system (ETS). Most SMEs are not on that list.

Decree 180 lets emission sources that have been allocated a quota pay to use forest carbon services to offset the portion above their quota. But "allocated a quota" is a distinct legal status set by the ETS framework, not an automatic right of every business. In practice, the list of facilities that must inventory emissions and receive quotas in the pilot phase is concentrated in high-emitting sectors (thermal power, steel, cement), not a garment workshop or a small processing facility.

This yields a practical distinction: if you have no quota, the credits you buy are a voluntary offset for ESG/brand commitments — not a compliance obligation, and not deducted from any quota. If you are subject to inventory and quota allocation, start by measuring your own emissions first; see our guide on GHG inventory Scope 1-2-3 for SMEs. Do not reverse the order: buying credits before you know your emissions is spending blind.

Table 3 — Three SME situations with forest carbon credits under Decree 180. Status as of 07/08/2026.

Situation	Who you are	What you may do	Where it counts
Have an emissions quota	ETS facility (usually large)	Use forest carbon services to offset above-quota emissions	ETS compliance obligation
No quota, voluntary buyer	SME with ESG/net-zero commitment	Buy credits via contract/exchange, confirmed by MAE	Voluntary offset, ESG/brand reporting
Forest owner	Agri-forestry SME, forest owner	Be a supplier: run a project, obtain and sell credits	Revenue; partly contributes to the NDC

Agri-forestry SMEs: the chance to become a seller

Direct answer: if your business owns or manages forest, Decree 180 opens a new revenue stream — but with measurement, verification and compliance costs, so run the cost side before dreaming of the revenue.

The decree lets forest owners cooperate and link with organisations and individuals to implement forest carbon projects, and share the resulting reductions and credits. This matters for forestry cooperatives and agri-forestry SMEs: you need not do every step yourself, but can partner with specialists to develop a project. Revenue from public-forest carbon credits is prioritised for forest protection and development, community livelihoods, project development and forestry databases (Eco-Business, 2026).

On funding: outstanding green credit reached nearly VND 828 trillion cumulatively by the end of Q1 2026 across 82 credit institutions, per State Bank of Vietnam data announced on 9 June 2026 — some of which may finance forestry and low-emission agriculture. We analyse how to access this capital in accessing green funds in Vietnam.

The 50% export cap and anti-double-selling: what they mean for price

Direct answer: the 50% export cap and the no-resale rule both tighten international supply and raise the quality of domestic credits. Both affect price and the reliability of the credits you buy.

Domestically-reported coverage notes the decree sets a maximum 50% export cap on forest carbon credits to ensure national emissions security and the 2050 net-zero commitment; international transfers must also follow the Government's separate rules on international exchange of emission reductions and carbon credits. The combined effect for SMEs: keeping at least half of credits at home increases domestic supply, in theory favourable to a domestic voluntary buyer; but confirmation and anti-double-selling raise transaction costs, so a "clean" traceable credit may cost more than the loose credits of the past — the price of trust. A cheap credit whose origin cannot be traced is useless when an ESG audit asks.

Greenwashing warning: credits do not replace cutting emissions

Direct answer: using forest carbon credits to claim "net-zero" while you have not measured or cut your own emissions is the shortest path to a greenwashing accusation. The right order is measure first, cut first, and offset only what you cannot cut.

The decree's own principle notes these activities must not affect Vietnam's international emission reduction commitments — offsetting is not a licence to emit more. At company level the logic is the same: a "carbon neutral" claim holds only if you have real inventory data, a reduction pathway, and use credits solely for the remainder. Three practical rules to avoid greenwashing: (1) do not say "net-zero" when you have only bought credits without an emissions inventory; (2) separate "emissions reduced" from "emissions offset" in your communications; (3) use only confirmed, traceable credits as Decree 180 requires. We discuss the legal and communication limits of green claims in green labels and anti-greenwashing for SMEs, and the reduction pathway in the Net Zero roadmap for SMEs.

What SMEs should do now

Direct answer: do not start by buying credits. Start by identifying your role and measuring your emissions — buying credits, if needed, is the last step, not the first.

Four steps in order: (1) determine your group in Table 3 — quota holder, voluntary buyer, or forest owner; (2) if you must inventory emissions, do a Scope 1-2-3 inventory first; (3) if buying voluntarily, buy only via contract or exchange, and require proof of MAE confirmation and the no-resale commitment; (4) if you own forest, cost the measurement–verification work before deciding on a project, and consider partnering with specialists.

GROW works with SMEs on exactly these four steps: reading your legal position in the carbon framework, building an emissions inventory as the base, connecting green finance, and designing an offset strategy that does not slide into greenwashing. If a "buy forest carbon to go net-zero" pitch has you confused, let us help you separate the real from the sales.

With Decree 180/2026, forest carbon credits finally have clear rules in Vietnam — but for an SME, buying credits only makes sense once you have measured and cut your own emissions first; if you have not, that credit does not buy carbon neutrality, only greenwashing risk.