Environmental Registration Under the Law on Environmental Protection

As environmental protection laws continue to be refined and administrative procedures for businesses are simplified, environmental registration has also undergone notable changes. In particular, under Resolution 66.19/2026/NQ-CP, several provisions on the competent authority and procedures for environmental registration have been adjusted to make things easier for businesses. So, under the Resolution, who must complete environmental registration? Let's look at the details in the article below.

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Environmental registration under Resolution 66.19/2026/NQ-CP

Article contents:

1. What is environmental registration?

Under Clause 9, Article 3 of the Law on Environmental Protection 2020: "Environmental registration means the registration by the owner of an investment project or of a production, business or service facility with the state management authority of matters relating to waste discharge and environmental protection measures of the investment project or production, business or service facility (hereinafter collectively referred to as investment projects and facilities)."

2. Legal basis for the environmental registration dossier

Previously, before Resolution 66.19/2026/NQ-CP, businesses preparing environmental registration dossiers and other environmental procedures generally relied on the following legal documents:

Law on Environmental Protection 2020
Decree 08/2022/ND-CP guiding the implementation of the Law on Environmental Protection
Decree 05/2025/ND-CP (amending and supplementing a number of articles of Decree 08/2022/ND-CP)
Decree 131/2025/ND-CP (on the division of authority between the two levels of local government in state management areas of the Ministry of Agriculture and Environment)
Decree 136/2025/ND-CP (on delegation and decentralization of authority in the field of agriculture and environment);
Circular 02/2022/TT-BTNMT (detailing the implementation of a number of articles of the Law on Environmental Protection)
Circular 07/2025/TT-BTNMT (amending and supplementing a number of articles of Circular 02/2022/TT-BTNMT)
Resolution 66.19/2026/NQ-CP (on cutting, decentralizing and simplifying administrative procedures and cutting and simplifying business conditions under the management of the Ministry of Agriculture and Environment).

*Note: From the date Resolution 66.19/2026/NQ-CP takes effect (18/05/2026), environmental registration dossiers must be prepared in accordance with the provisions of this Resolution.

>>> Quick read: Everything you need to know about environmental registration under the new regulations: HERE

Resolution 66.19/2026/NQ-CP on cutting administrative procedures under the management of the Ministry of Agriculture and Environment

3. Who must complete environmental registration

Under Resolution 66.19/2026/NQ-CP, there are 2 cases of environmental registration: Provincial-level environmental registration and Commune-level environmental registration. Which level applies depends on the scale and operating capacity of the project or facility.

Entities subject to provincial-level environmental registration: Investment projects and facilities that generate wastewater requiring treatment before discharge with a total flow of 50 m³/day or more, or that generate dust and exhaust gas requiring treatment before discharge with a total flow of 20,000 m³/hour or more, shall register with the provincial People's Committee;
Entities subject to commune-level environmental registration: Investment projects and facilities whose flow of wastewater and exhaust gas requiring treatment before discharge does not fall under point a of this clause shall register with the commune-level People's Committee.

Below is a summary table of the 2 cases of environmental registration under Resolution 66.19/2026/NQ-CP.

Regulations on cases requiring an environmental registration dossier — Regulations on entities required to file environmental registration under Resolution 66.19/2026/NQ-CP

4. When is an environmental registration required?

Under Clause 6, Article 49 of the Law on Environmental Protection 2020, the timing of environmental registration is as follows:

Investment projects specified in point a, clause 1 of this Article that are subject to an EIA must register before official operation.
Investment projects specified in point a, clause 1 of this Article that are not subject to an EIA must register before the competent authority issues the construction permit (where a construction permit is required), or before discharging waste into the environment (where no construction permit is required).
Registration must be completed within 24 months from the date this Law takes effect for production, business and service facilities (specified in point b, clause 1, Article 49). The Law took effect on 01/01/2022, so the deadline for environmental registration was 31/12/2023. Businesses need to be aware of this so they can comply proactively.

When to register — *Regulations on the timing of environmental registration*

5. Content of the environmental registration

Under Clause 4, Article 49 of the Law on Environmental Protection 2020, the environmental registration covers:

General information about the investment project or facility;
The type of production, business or service, technology, capacity, products, raw materials, fuels and chemicals used;
The types and volumes of waste generated;
A plan for collecting, managing and treating the waste;
Proposed commitments to carry out environmental protection work.

*Content of the environmental registration*

The environmental registration is prepared according to Form No. 47 of Appendix II of Circular 02/2022/TT-BTNMT.

6. Authorities receiving environmental registration dossiers

Previously, under Clause 7, Article 49 of the Law on Environmental Protection 2020, the receiving authority was the commune-level People's Committee, specifically:

Receiving dossiers, inspecting and handling violations of environmental protection law; providing guidance on and resolving environmental protection petitions; and updating environmental registration data.
Receiving dossiers for investment projects and facilities located in 2 or more commune-level administrative units.

Responsibilities of the commune-level People's Committee:

a) The commune-level People's Committee receives environmental registration dossiers from owners of investment projects and facilities in 3 main ways: in person, by post, or electronically through the online public service system.

b) The commune-level People's Committee updates environmental registration data in the national environmental information system and database.

c) Inspecting and handling violations of environmental protection law by registered organizations and individuals in accordance with the law.

d) Providing guidance on and resolving environmental protection petitions relating to the content registered by organizations and individuals.

Currently, under Resolution 66.19/2026/NQ-CP, the authorities receiving environmental registration dossiers are the provincial People's Committee or the commune-level People's Committee (the dossier is submitted at the corresponding level depending on the scale and operating capacity of the business and the amount of waste generated).

7. Dossier and conditions for environmental registration

Below is information on the dossier components and conditions for environmental registration:

7.1. Environmental registration dossier components

- One (01) environmental registration document of the owner of the investment project or facility, following Form No. 47, Appendix II issued with Circular 02/2022/TT-BTNMT of the Ministry of Natural Resources and Environment;

- One (01) copy of the decision approving the appraisal results of the environmental impact assessment report of the investment project or facility (where the investment project or facility has an approved EIA report as prescribed).

7.2. Conditions for environmental registration

- The owner of the investment project or facility submits the environmental registration dossier to the commune-level People's Committee where the investment project or facility is located.

- During operation, if there are changes to the registered content, the owner of the investment project or facility is responsible for re-registering before making those changes.

- Where a change in the scale or nature of the investment project or facility makes it subject to an environmental impact assessment or an environmental permit, the owner is responsible for complying with the regulations on environmental impact assessment and environmental permits under the Law on Environmental Protection.

Above is some information on "Environmental registration under the Law on Environmental Protection". Hop Nhat Environmental Services has many years of experience consulting on a wide range of environmental procedures. For environmental registration dossiers, once clients provide all the necessary information and legal documents, we draft and submit the dossier quickly, so clients obtain a compliant dossier in a short time.

If you need advice on environmental registration or other environmental compliance dossiers, please contact us directly via Hotline 0938.857.768 or click the box below for dedicated support.

8. Reference materials

In this article, we used reference material from legal documents and several other sources:

Law on Environmental Protection 2020;
Decree 08/2022/ND-CP (detailing a number of articles of the Law on Environmental Protection);
Decree 05/2025/ND-CP (amending and supplementing a number of articles of Decree 08/2022/ND-CP);
Decree 131/2025/ND-CP (on the division of authority between the two levels of local government in state management areas of the Ministry of Agriculture and Environment);
Decree 136/2025/ND-CP (on delegation and decentralization of authority in the field of agriculture and environment);
Resolution 66.19/2026/NQ-CP (on cutting, decentralizing and simplifying administrative procedures and cutting and simplifying business conditions under the management of the Ministry of Agriculture and Environment);
Documents from the Customer Development Department - Hop Nhat Environment;
Compiled from various sources.

*Note: The information and topics we provide are for reference only. When applying laws and regulations on natural resources and the environment, please check and stay updated on the validity of each relevant legal provision and legal document to apply them correctly!