VIETNAM Trends and Developments Contributed by: Adam Moncrieff and Thuy Huynh, Orrick
The concern for the market is not only the money out- standing on existing projects; it is the perception that agreed commercial terms might be revisited after pro- jects have been built and financed. That perception matters for future greenfield investment, refinancing and M&A in operating renewables. Buyers and lenders considering operating renewable assets should therefore carry out enhanced diligence on feed-in tariff eligibility, commercial operation date evidence, construction acceptance, land approvals, planning compliance, fire safety, EVN correspondence and payment history. A fair and practical resolution of legacy feed-in tariff disputes would send an impor- tant signal. It would show that Vietnam can address past implementation problems without undermining confidence in future greenfield project development. The DPPA regime is getting closer to getting it right Vietnam’s regulations for DPPAs for large-scale elec- tricity users have been a work in progress for several years. Vietnam first introduced a pilot DPPA mecha- nism under Decision No 08/2020/QD-TTg dated 5 March 2020, but the framework was limited in scope, was restricted to a small number of participants and lacked the commercial and regulatory detail needed to support large-scale transactions. Subsequent drafts and revisions sought to broaden eligibility and clarify pricing, but there remained uncertainty around grid- use charges, settlement mechanisms and the role of EVN. For a long time, no significant across-the-grid direct electricity sales transactions were completed. Vietnam now has two principal DPPA models. The first is the private-wire model, where a renewable ener- gy generator sells electricity directly to a customer through privately developed transmission infrastruc- ture. The second is the grid-based or virtual model, where power is sold through the national grid. It is the second model which is the more important to start to move Vietnam to a more competitive electricity sales market where large-scale users can have real choice in electricity purchase beyond the monopoly state- owned utility. Achieving a first virtual DPPA transaction is impor- tant, and this happened in June 2026 with Samsung
Electronics Vietnam Thai Nguyen announcing it had begun purchasing renewables-generated electricity through the national-grid DPPA mechanism from the TTC Duc Hue 2 solar power plant. One transaction does not make a market, but it does show that com- mercial electricity generators and buyers can do deals under Vietnam’s DPPA regime. It was regulatory updates in June 2026 that enabled this to happen. Decree No 243 in 2026 clarified that the mechanism covers renewable energy generators, large electricity consumers and retail electricity units in industrial-zone and similar models. It also expanded eligible large consumers beyond production custom- ers to include users such as data centres, electric vehicle charging stations and battery swapping facili- ties, subject to the relevant connection and eligibility requirements. Circular No 29 of the MOIT in 2026 was also impor- tant. It reduced the average monthly consumption threshold for large electricity consumers using the direct transmission DPPA model from 200,000 kWh to 20,000 kWh, while keeping the 200,000 kWh thresh- old for the national-grid model. It also clarified the treatment of renewable plants participating in virtual DPPAs as direct market participants, while plants sup- plying through direct transmission DPPAs are treated as indirect participants. Bankability questions remain, including payment set- tlement issues, curtailment, EVN or NSMO charges, market-price exposure, credit support, change in law, termination payments and minimum consumption commitments. DPPAs are moving in the right direc- tion, and the market will become more confident if future regulatory change can make grid-use charges and EVN’s role more transparent, predictable and lim- ited to system and transmission services. BESS becomes an important investment category Battery energy storage systems (BESS) are now included in Vietnam’s power sector planning. Storage is no longer an optional add-on for renewable pro- jects; it is becoming an important part of a planning system which may face more intermittent generation, more industrial load and more pressure on transmis- sion infrastructure.
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