Circular 64/2026/TT-BCT Tightens Energy Audits From November 20

Unofficial English summary for reference only. Not a legal translation and not legal advice. The Vietnamese text linked at the end of this page is authoritative.

What the document does

Circular 64/2026/TT-BCT writes the operating rules for Vietnam’s energy-efficiency compliance regime. It covers five groups of duties: the annual lists of key energy users; the annual and five-year energy-saving plans and implementation reports those users must file; the annual energy-use plans and reports of state-budget-funded bodies that consume at least 100,000 kWh of electricity a year; the energy-management model every key facility must apply; and the procedure and report contents for energy audits.

The circular implements the amended Law on Economical and Efficient Use of Energy (Law 77/2025/QH15) and Government Decree 30/2026/ND-CP, which detail the law’s application. It is the instrument that turns the amended law’s obligations into filing deadlines, report forms and audit cycles.

What changes in practice

None of the duties below applies yet; they take effect on November 20, and this section describes what the circular will require from that date. The substance lies in the calendar. Before January 15 of each year, key energy users on the approved list and qualifying state-budget bodies must report the previous year’s energy consumption to their provincial People’s Committee. The annual plan cycle runs to April 30: by that date each year, they must build the current year’s saving plan and report the previous year’s plan implementation. The five-year cycle has its own deadline: before April 30 of the first year of each cycle, key facilities must build the next five-year plan and report the previous cycle’s results. All of this runs on the national energy-data system at dataenergy.vn, using the circular’s appended forms.

The audit duty is the most stringent requirement. Every key energy user must complete a mandatory energy audit once every three years, and must send the audit report to the provincial People’s Committee within 30 days of issuance, in paper or electronic form through dataenergy.vn. The report must contain the survey and measurement data, the specific energy consumption (SEC) calculation, the facility’s energy balance diagram, the efficiency assessment, the saving-potential analysis and the proposed measures with investment analysis. A newly listed facility has one year from its listing decision to complete its first audit.

The energy-management model becomes a defined duty rather than a recommendation. Key facilities must publish energy targets and policies, build annual and five-year plans, and appoint an energy manager meeting the criteria of Article 35(1) of the Energy Efficiency Law. They must also maintain compliant metering to track consumption monthly, set energy baselines and performance indicators, run the audit cycle, and train workers periodically. Economic groups with several key facilities may organize the model at group level while retaining full duties at each facility.

What changed from the previous rules

Circular 64 expressly replaces Circular 25/2020/TT-BCT of September 29, 2020. The core machinery carries over: the 2020 circular already established the annual key-user lists, the annual plans and implementation reports, and the mandatory energy audits. Readers should not mistake the November 20 date for the invention of the audit duty; the three-year audit cycle is a continuation, not a new invention.

What is new is the formalized energy-management model as a standalone chapter with six required contents, from published targets to the energy manager appointment. The 2020 circular’s title covered plans, reports and audits; the 2026 circular’s title adds the management model, and Article 6 turns it into an enforceable facility-level duty with provincial inspection behind it. The five-year planning cycle with a fixed deadline is also new, as is the updated legal basis in the amended 2025 Energy Efficiency Law and its 2026 implementing decrees.

The transition is gentle on one point: energy audit reports issued before November 20, 2026, remain valid for three years from their issuance date. No facility is forced to re-audit on day one.

Who is affected

The circular applies to key energy users, meaning facilities on the annually approved provincial lists; to state-budget-funded bodies, in whole or in part, consuming at least 100,000 kWh of electricity a year; to energy-audit organizations; and to other related bodies and individuals. It does not apply to defense and security bodies. Energy intermediaries that transport, trade or distribute energy do not count traded volumes toward their consumption.

Provincial People’s Committees carry the administrative load: they compile, approve and issue the year N-1 key-user lists before March 31 of year N, report them to the Ministry of Industry and Trade, and file the annual compliance assessment before June 15. Provincial power companies must cooperate by supplying customer electricity-consumption data for list building, subject to data-protection rules.

Notes for investors and operators

For industrial investors, the circular will convert energy efficiency from a reporting chore into a managed system with named deadlines. The audit every three years will be the compliance anchor: the report’s saving-potential analysis and investment analysis will effectively become the facility’s documented improvement roadmap, and the provincial committee will be able to order a deficient report to be redone. The group-level management option in Article 6 is the practical relief for conglomerates, one system across several listed facilities instead of several parallel ones.

EV charging operators and data center developers should note the 100,000 kWh threshold for state-budget bodies and the metering duties: any facility approaching key-user scale should be tracking SEC and energy baselines now, because the first filing deadlines under the new forms will arrive within months of the November 20 effective date.

What businesses should do next: check whether your facility is on the current provincial key-user list; if newly listed, calendar the one-year deadline for the first audit and the energy-management model; if already listed, confirm your most recent audit report’s issuance date against the three-year rule and the transition clause; put in place metering that can produce monthly consumption, SEC and energy-balance data in the circular’s forms; and register reporting access on dataenergy.vn before the January 15 consumption-report deadline.

Sources and the official text

Thu Vien Phap Luat (legal database), full text of Circular 64/2026/TT-BCT in Vietnamese, signed September 30, 2026, effective November 20, 2026, replacing Circular 25/2020/TT-BCT; operative provisions verified against Articles 1, 2, 4 through 8 and 12, including the transition clause for pre-existing audit reports. https://thuvienphapluat.vn/van-ban/Tai-nguyen-Moi-truong/Thong-tu-64-2026-TT-BCT-ke-hoach-su-dung-nang-luong-tiet-kiem-hieu-qua-727831.aspx

Government portal (baochinhphu.vn), summary of the circular’s new rules on energy-saving plans and energy audits. https://baochinhphu.vn/quy-dinh-moi-ve-lap-thuc-hien-ke-hoach-su-dung-nang-luong-tiet-kiem-hieu-qua-102261009162749528.htm

About this explainer: VoltViet prepared this summary in English from the official Vietnamese text so that investors and operators can follow what the document does. It is a reading aid, not a translation of record and not legal advice. Where any wording here differs from the Vietnamese text, the Vietnamese text governs. For decisions with legal or financial consequences, rely on the official text linked above and take advice from a qualified Vietnamese lawyer.

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