Virtual DPPA off-takers

• Virtual DPPA
• Large power consumers using electricity for production or EV charging that meet the applicable consumption threshold.
• Cluster power retailers authorized by large power consumers.
• Physical DPPA
• Large power consumers meeting the applicable consumption threshold (not limited to specified industries/sectors).

• Virtual DPPA – Expanded vs. Decree 57
• Cluster power retailers (excluding urban and free trade zones) added.

Can participate on their own behalf; no authorized from large power consumers required.

• Large power consumers: Expanded to include data center operators and battery swapping operators for transportation.
• Physical DPPA – Expanded vs. Decree 57, and broader than Virtual DPPA:
• Cluster power retailers (including urban and free trade zones) added.

Of note: Eligibility remains subject to meeting the average monthly consumption threshold:¹

• Physical DPPA: 200,000 kWh/month, reduced to 20,000 kWh/month from 20 July 2026.
• Virtual DPPA: 200,000 kWh/month.

Cap on electricity price for Physical DPPA

Capped at the ceiling price in the applicable electricity generation price bracket.

No cap – Pricing at the contractual parties’ discretion.

Side note: this is not a substantive change introduced by Decree 243. Rather, Decree 243 simply reflects the price-cap removal already stipulated in Resolution 253 (effective 1 March 2026).²

Sale of power surplus for Physical DPPA

• If sold to EVN:

Volume cap:

• For RTS: 20% of the actual power generated.
• For other sources of renewable energy: NO cap.

Regulated pricing:

• For RTS: the lower of:
• the average electricity price market in the preceding year; and
• the ceiling price under applicable ground-mounted solar power generation price framework.
• For other sources of renewable energy: at parties’ agreement but capped at applicable regulated ceiling generation price.
• If sold to cluster power retailers:

Volume cap: NO cap.

Regulated pricing: Capped at the ceiling price in the terrestrial solar power generation price bracket.

Decree 243 significantly increases the cap on RTS surplus electricity sold to EVN (from 20% to 50%).

For surplus electricity sold to cluster power retailers, the pricing is no longer subject to any statutory cap, making both volume and pricing up to the parties’ contractual discretion.

• If sold to EVN:

Volume cap:

• For RTS: 50% of the actual power generated.
• For other sources of renewable energy: Remains NO cap.

Regulated pricing: No change.

• If sold to cluster power retailers:

Volume cap: NO cap.

Regulated pricing: Pricing at the contractual parties’ discretion.

Virtual DPPA registration process

Step-by-step process:

• DPPA Registration: Submit the DPPA registration dossier to National System and Market Operator (NSMO).
• Review Process: NSMO forwards the dossier to the relevant EVN entity for review.
• NSMO Notification: NSMO issues a notice on the PPA conversion timeline.
• Execution of Agreements: Execute the Contract-for-Difference (CfD), Market PPA (between EVN entity and GENCO³) and Retail PPA (between EVN entity and off-taker).
• Preparation for Virtual DPPA Participation: GENCO and the off-taker fulfil all conditions to participate in the Virtual DPPA model, including GENCO’s registration to participate in Vietnam Wholesale Electricity Market (VWEM).
• DPPA Commencement: Obtain the DPPA Commencement Notice, which officially starts the Virtual DPPA.

All into one process.

• Single registration process: Virtual DPPA registration and VWEM participation registration are generally consolidated into a single process.
• Single dossier: Includes:
• Documents evidencing satisfaction of facility requirements;
• CfD, Market PPA and Retail PPA; and
• VWEM participation registration documents.
• Single review: NSMO reviews the integrated dossier and, once all requirements are met, issues the DPPA Commencement Notice.

RTS registration and development certificate (RTS Certificate) requirement for Physical DPPA

Whether RTS Certificate is required for Physical DPPA is NOT CLEAR:

• Under Decree 61/2025, an RTS Certificate may be issued for projects under the Physical DPPA model and may be a prerequisite for obtaining an Electricity Operation License.⁴
• That said, no regulatory procedure for obtaining such certificate has been issued for this model.

No RTS Certificate required for Physical DPPA.

RTS definition

The underlying structure for an RTS could be interpreted as any construction work.

The underlying structure for an RTS must be a house or a house-like construction.

This potentially narrows the types of structures that qualify for rooftop solar. Accordingly, installations on structures such as canopies, shelters or other non-building constructions may no longer qualify as rooftop solar. Nevertheless, as the term “house-like construction” is not defined under Vietnamese law, it remains to be seen how broadly this concept will be interpreted and applied in practice.

Sale of power surplus

• Eligible purchasers: EVN designated entities
• Volume cap:
• For RTS:
• 20% of the RTS’s electricity output, based on solar irradiance.
• No cap for mountainous, border and island areas not supplied with electricity by the national power system.
• For other sources of renewable energy: 10% of the electricity output.
• Pricing rules:
• For RTS

Electricity price: the lower of:

• the average electricity price market in the preceding year; and
• the ceiling price under applicable ground-mounted solar power.

Surplus electricity exceeding the agreed volume: Payment limited to the agreed volume (i.e., excess electricity is not compensated).

• For other sources of renewable energy: Except for small-scale renewable energy power plants, electricity price shall be the lower of:
• the average electricity price market in the preceding year less electricity service costs; and
• the applicable regulated ceiling generation price.
• EVN’s right to refuse surplus power purchase: Applicable only to SP&SC RTS with an installed capacity of less than 100 kW, where the purchase would result in overloading of the low- or medium-voltage grid.

The key changes to Decree 58/2025 are:

• expanding eligible purchasers beyond EVN to include qualifying private-grid operators;
• increasing the surplus power sale cap for RTS from 20% to 50% (or beyond 50% depending on grid safety until 31 December 2030), while limiting the cap to 10% for rooftop solar on mixed-use land.
• clarifying that the applicable price cap is based on the ground-mounted solar price framework, excluding the BESS price framework;
• expanding EVN's right to refuse surplus power purchases where they would overload the low- or medium-voltage grid, regardless of the system's installed capacity.

See further details below:

• Eligible purchasers – Expanded beyond EVN to include private-grid operators

Private-grid operators must:

• hold an electricity operation license for electricity distribution or retail; and
• lawfully own the private grid through which electricity generated from SP&SC renewable energy sources is transmitted before connecting to the national grid.

Practically, this expansion appears aimed at enabling cluster electricity retailers to acquire power surplus from SP&SC renewable energy generators.

• Volume cap – Significant increase for RTS vs. Decree 58/2025:
• For RTS:
• 50% of the RTS’s electricity output, based on solar irradiance.
• Temporary exception (until 31 December 2030: May exceed 50%, subject to availability and safe grid operation at the connection point
• No cap for mountainous, border and island areas not supplied with electricity by the national power system (no change vs. Decree 58/2025).
• For other sources of renewable energy: Still 10% (no change vs. Decree 58/2025).
• Pricing rules:
• For RTS:

Electricity price: the lower of:

• the average electricity price market in the preceding year; and
• the ceiling price under applicable ground-mounted solar power without BESS price framework.

Surplus electricity exceeding the agreed volume: No change vs. Decree 58/2025.

• For other sources of renewable energy: No change vs. Decree 58/2025
• EVN’s right to refuse surplus power purchase: Expanded to all SP&SC RTS (no capacity threshold), where the purchase would result in overloading of the low- or medium-voltage grid.

RTS Certificate

• Required for SP&SC RTS connected to the national grid with:
• installed capacity ≥ 1,000 kW; or
• installed capacity < 1,000 kW with surplus power sale (except exempt cases).
• Application dossier: Including, among others, RTS-related documents (e.g., investment decision, construction permit, fire safety approval, completion records, environmental license/registration).

• Not required for SP&SC RTS with no power surplus sale.
• Application dossier simplified: RTS-related documents are limited to the fire safety acceptance certificate or fire safety design appraisal approval (as applicable).

Application for sale of power surplus

Application dossier: Including, among others, RTS-related documents (e.g., Construction completion dossier construction, approvals on environmental, fire safety and commissioning).

Application dossier simplified – RTS-related documents are limited to the fire safety acceptance certificate or fire safety design appraisal approval (as applicable).

Land use purpose of RTS SP&SC

No specific regulations

Where SP&SC RTS is constructed on mixed-use land:

• SP&SC RTS regulations will apply; except that:
• Surplus power sale is capped at 10% only (instead of 50% or more).

RTS definition

Same as in the table above for key DPPA changes.