Green Public Procurement (GPP) is an irreversible trend in the context of an escalating global environmental crisis and increasingly severe climate change. In Viet Nam, alongside the refinement of the legal framework and international commitments to achieving net-zero greenhouse gas emissions by 2050, policies to promote GPP have been promulgated and implemented. In this process, the role of the State Audit Office of Viet Nam (SAV) – the supreme authority for public financial oversight – is particularly critical in ensuring that GPP is conducted in compliance with regulations, in a transparent, effective, and accountable manner.

1. Green Public Procurement in Viet Nam: Legal Framework and Practical Orientation

In Viet Nam, Green Public Procurement (GPP) has been progressively institutionalised and integrated into key legal instruments in order to advance the objectives of green growth, environmental protection, and sustainable development.

The first significant legal foundation is the Law on Environmental Protection 2020 stipulates: “Priority shall be given to the implementation of green procurement for investment projects and tasks utilising State budget resources, as prescribed by the Government.” This marked the first time that the concept of “green procurement” was formally codified within the Vietnamese legal system, representing a significant milestone in both policy awareness and legislative institutionalisation.

Subsequently, the Law on Bidding 2023 inherited and further reinforced the principle of prioritising environmentally friendly products and services in public procurement activities. Specifically, the Law expressly sets forth the principle of procurement as “encouraging the procurement of environmentally friendly products and services, thereby promoting sustainable development.” This provision constitutes not only a strategic policy direction but also a firm legal basis for Owners and procuring entities to incorporate environmental criteria into bidding documents and the bid evaluation process.

In parallel, Decree No. 08/2022/ND-CP of the Government in 2022, providing detailed guidance on certain provisions of the Law on Environmental Protection, also contains explicit regulations on GPP. The Decree requires State agencies, when organising procurement and tendering, to integrate environmental criteria into bidding documents, particularly in sectors such as construction, information technology, medical equipment, and office supplies. This serves as a crucial operational step to concretise the statutory provisions and to facilitate effective implementation by executing entities.

Beyond the mere improvement of the legal framework, the Government of Viet Nam has adopted a long-term strategy for greening public finance through the issuance (in 2021) of the National Strategy on Green Growth for the 2021–2030 period, with a vision to 2050. Within this framework, a specific target has been set: by 2030, at least 35% of the total value of public procurement funded by the state budget shall comprise products, goods, and services meeting environmental criteria, with this proportion rising to 50% by 2045. This reflects the Government’s strong commitment to leveraging public procurement as a catalyst for promoting sustainable consumption and production across the entire economy.

2. The role of the SAV in overseeing, shaping, and promoting Green Public Procurement in Viet Nam

As the nation’s Supreme Audit Institution, the SAV not only fulfils its mandate to oversee the management and utilisation of public finance and public assets in compliance with the law and in accordance with principles of economic prudence, but is also progressively expanding the scope, content, and methodologies of its audits to meet the demands of sustainable development in the current era.

In the context of the Government of Viet Nam’s strong commitment to green growth and achieving net-zero emissions by 2050, the SAV’s mandate extends beyond the conventional “right–wrong” assessment of expenditure. It now also encompasses evaluating the extent to which environmental and social criteria are integrated into the use of state budget resources, particularly in large-scale public investment projects and procurement packages.

Incorporating criteria such as greenhouse gas emissions, resource efficiency, product life-cycle considerations, and impacts on biodiversity into audit examinations will enhance the quality of audit recommendations. This, in turn, can drive institutional reforms and safeguard public assets not only from a financial perspective, but also from an environmental standpoint – a dimension traditionally underrepresented in conventional auditing methodologies.

In practice, the SAV has already initiated several audit activities incorporating environmental aspects. Notable examples include:

1. The audit of investment, procurement, application of software, and contracting of information technology services at selected ministries and agencies for the period 2020–2022, which not only assessed compliance in procurement and implementation of digital solutions, but also examined the potential for selecting energy-efficient systems that reduce emissions over the full life cycle of software and equipment, in alignment with the objectives of green public procurement.

2. The audit of the management and utilisation of funding for the procurement of national reserve goods for the period 2020–2021, which focused on assessing suppliers’ ability to meet environmental protection requirements, the traceability of products, and compliance with sustainable goods standards in procurement financed by the state budget.

3. Notably, in the audit of the procurement, management, and utilisation of medicines, medical supplies, and medical equipment, the SAV actively integrated environmental criteria into the audit process. Specifically, the SAV assessed the compliance with the Law on Environmental Protection 2020 and the said Decree No. 08/2022/ND-CP, which explicitly stipulate the requirement to give priority to green procurement in projects funded by the state budget. On this basis, the SAV recommended that ministries and agencies promptly issue or refine guidelines for applying preferential mechanisms for environmentally friendly products, while also proposing the inclusion of mandatory product life-cycle criteria in bidding documents for projects in the information technology and healthcare sectors.

4. In addition, a series of thematic audits relating to environmental matters—such as the audit of municipal solid waste management; the audit of the operational effectiveness of the Forest Protection and Development Fund in various localities; the audit of forest protection and development activities and the use of forestry land; and the audit of budgetary expenditure for the climate change response and green growth programme—have indirectly addressed aspects related to green public procurement. These have included evaluating environmental criteria in public investment, the efficiency of resource utilisation, and the transparency of contractor and service provider selection.

Accordingly, although the SAV has not yet conducted a dedicated thematic audit exclusively on green public procurement, it has nonetheless demonstrated a proactive role in progressively integrating environmental considerations into the audit of state budget execution, particularly in sectors with high emission risks or direct links to public investment. This is a necessary direction to advance the greening of public finance and is consistent with the State’s sustainable development policies.

The expansion of audit scope from assessing compliance and financial regularity to evaluating the integration of sustainable development criteria—including environmental indicators—is being progressively applied by the SAV through its medium-term audit strategy. The objective is not only to ensure the efficient use of the state budget but also to improve institutional quality and promote green transition in public policy.

In particular, in recent years, the SAV has intensified its application of information technology and big data in audit activities. Through the National E-Procurement System (e-GP), the SAV has deployed advanced data analytics tools, including artificial intelligence (AI), to support risk-based audit sampling, detect anomalies in procurement processes, and gradually build a platform for proactive, continuous monitoring. These developments create favourable conditions for systematically incorporating “green” criteria into the audit processes of state-funded procurement projects in the near future.

In parallel with the modernisation of its operations, the SAV is also actively promoting transparency and accountability by considering the development of a public-facing dashboard displaying audit data on the extent of compliance with environmental criteria in public investment projects. At the same time, the SAV is working towards establishing a multidimensional policy feedback mechanism to ensure that audit recommendations are received, addressed, and effectively utilised in the process of formulating and amending legal regulations.

Beyond its core function of financial oversight, the SAV is progressively assuming a policy-shaping role, serving as a bridge between key stakeholders such as the National Assembly, the Government, ministries, enterprises, and civil society. This forms the foundation for green public auditing to evolve from a purely technical undertaking into a catalyst for institutional reform, thereby advancing the development of transparent, accountable, and sustainable green public finance in Viet Nam.

3. Challenges in auditing Green Public Procurement

Although the SAV has progressively integrated environmental considerations into its audit activities and identified green auditing—including green public procurement—as one of the priority orientations in its forthcoming Environmental Audit Strategy, in practice, the implementation of stand-alone thematic audits on green public procurement continues to face significant challenges in terms of institutional frameworks, capacity, and operational conditions.

The first and most fundamental challenge lies in the absence of a unified system of criteria, indicators, and assessment tools for determining the “greenness” of public procurement activities. At present, there has been a lack of a specific set of green audit criteria, resulting in considerable uncertainty in selecting audit subjects, defining audit scope and content, and determining appropriate methodologies. While current laws and regulations refer to the requirement to prioritise environmentally friendly products, these provisions have yet to be translated into quantifiable indicators or sufficiently clear technical guidance for auditors to apply in practice.

Recently, Viet Nam issued Decision No. 21/2025/QD-TTg to establish environmental criteria and procedures for certifying investment projects classified as "green." This Decision serves as a foundational basis for developing specific criteria to support the implementation of green auditing practices.

In addition, the lack of transparent and comprehensive information on “green” products and services constitutes a major obstacle. Data on life-cycle costs, the origin of raw materials, energy consumption levels, and the overall environmental impact of items procured through public procurement have not yet been standardised or widely disclosed. This not only hampers the process of sampling and assessing environmental performance, but also undermines the ability to compare procurement packages and contractors within the same sector.

Nevertheless, as the supreme audit institution responsible for public financial oversight, the SAV continues to play a central role in promoting green public spending and sustainable development. The gradual improvement of the legal framework, the development of green audit criteria, investment in capacity, and the enhanced application of technology in data analytics are key factors that will enable the SAV to progressively overcome current challenges and successfully implement green public procurement audits in the near future.

4. Solutions to strengthen the SAV’s role in auditing Green Public Procurement

To effectively fulfil its role in overseeing and promoting green public procurement, the SAV needs to modernise its audit approach by integrating environmental and sustainable development considerations, updating its practices in line with international auditing standards, investing in human resources and technology, and fostering multidimensional policy dialogue to enhance oversight effectiveness and accountability in public financial management.

As an independent supreme audit institution operating solely in accordance with the law, the SAV plays a critical role in ensuring that public expenditure is not only financially efficient but also contributes positively to the nation’s sustainable development objectives, as well as to the rigorous implementation of Viet Nam’s international commitments—most notably, the target of achieving net-zero emissions by 2050.

First, the SAV should progressively adopt and apply international auditing standards, particularly International Organisation of Supreme Audit Institutions (INTOSAI) Guidance No. 5280, which addresses public procurement auditing from three perspectives: compliance audit, financial audit, and performance audit. The assessment of the effectiveness of “green” objectives in public procurement should be guided by criteria such as life-cycle cost efficiency, the extent of greenhouse gas emission reductions, and the capacity to stimulate the development of sustainable domestic products and services markets.

Second, it is essential to develop and promulgate, at the earliest opportunity, a set of green audit criteria to serve as a legal and professional foundation for assessing the environmental friendliness of products and services in public procurement packages. This process will require coordination among the Ministry of Finance, the Ministry of Agriculture and Environment, and independent expert organisations. The criteria set could draw upon international frameworks such as ISO 20400 on sustainable procurement or guidance issued by the INTOSAI Working Group on Environmental Auditing (WGEA). In parallel, strengthening international cooperation within the frameworks of ASOSAI, INTOSAI, and specialised working groups will enable the SAV to gain more rapid access to modern auditing methodologies, thereby enhancing the quality of green audits.

Third, the training and professional development of auditors is crucial. Training content should focus on topics such as green procurement, the circular economy, product life-cycle auditing, environmental impact valuation, as well as data analysis skills and the use of digital tools. Enhancing training cooperation with experienced audit institutions worldwide will help narrow the gaps in expertise, methodology, and practical implementation.

An indispensable element is the application of information technology and big data analytics to support risk-based audit sampling, continuous monitoring, and detection of anomalies in procurement activities. The SAV should continue investing in the development of advanced data analytics platforms capable of integrating information from national systems such as the e-GP, as well as from relevant ministries and agencies, to construct a comprehensive picture of the “greenness” of public expenditure.

Fourth, due attention should be given to communication and awareness-raising on green public procurement as an integral component of the green audit strategy. The SAV could take a proactive role in disclosing audit results relating to environmental issues, organising policy dialogue forums, and providing information to the National Assembly, state agencies, and civil society organisations.This would generate positive pressure on relevant entities to enhance accountability and improve procurement processes. Such actions would not only help disseminate the message of “public spending for the environment” but also reinforce the SAV’s policy-shaping role in the country’s sustainable development process.