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Carbon Neutral Contributes to New Paper on Vietnam’s Forest Carbon Pricing Framework

BY

Renee McMahon

Date

September 2026

Vietnam took a significant step this year toward a functioning forest carbon market. In May 2026, the government issued Decree No. 180/2026/NĐ-CP on forest-based carbon sequestration and storage services, followed in July by Circular No. 31/2026/TT-BNNMT, which establishes methods for valuing forests and determining payment levels for forest carbon, particularly from state-owned forests.

Together, the two instruments start to resolve questions that have held the market back for years: who owns emission-reduction credits, how projects get registered, and how forest carbon should be priced.

Carbon Neutral International Partnerships Manager Rebecca Pearse has contributed to a new discussion paper examining what these rules will mean in practice. Co-authored by Pham Thu Thuy, Tran Hong Nhung and John Kandulu from Flinders University, Forest Carbon Pricing in Vietnam: From Policy to Practice is an early assessment of Circular 31 since it came into effect.

The paper draws on consultations with 12 experts and practitioners across international and domestic businesses, banking and finance, development organisations, research institutes and government agencies, gathered between June and July 2026. In the absence of much transaction data to draw on yet, these perspectives offer an early read on how the Circular is likely to play out for the people who actually have to work with it.

Rebecca’s contributions, on behalf of Carbon Neutral, centred on the project developer and investor perspective, looking closely at the distinction between what a forest carbon project costs to run and what its credits are actually worth on the market, and drawing on relevant lessons from Australia’s ACCU Scheme about market pricing, government intervention and price transparency to inform that analysis. They also examined how opportunity costs and buffers should be treated in pricing, what evidence is needed to support a credible market price and the governance required to keep pricing of public forest carbon transparent and defensible.

The findings point to real opportunities in Vietnam’s forest carbon market, alongside some open questions for government, forest owners, project developers, investors, financial institutions and carbon buyers to work through as implementation continues. As the authors note, there’s more empirical work to be done; this paper is an early, evidence-based contribution to a conversation that will keep developing as Circular 31 meets the real world.

Read the full discussion paper, published through Flinders University, below.

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