Can SMEs jointly implement a common project to share the costs of Measurement, Reporting and Verification (MRV)?

This collaborative model is one of the most effective approaches for Small and Medium-sized Enterprises (SMEs). It is officially recognized in international carbon markets as a Programme of Activities (PoA), also known as a grouped project. Vietnamese law provides a clear legal framework for this model, enabling SMEs to overcome common barriers to market entry.

PoA mechanism

The Programme of Activities (PoA) mechanism operates under a "hub-and-spoke" structure designed to aggregate small-scale climate projects. A central Coordinating/Managing Entity (CME), which can be an industry association, a consulting firm, or a large corporation, takes the lead. This CME is responsible for developing and registering a single framework "programme" with a relevant authority, such as Verra, Gold Standard, or Vietnam's national body. Individual Small and Medium-sized Enterprises (SMEs) with similar emission reduction activities, such as installing rooftop solar panels, constructing biogas digesters, or adopting specific energy-saving technologies across multiple sites, can then join this pre-approved programme, with each participating project being considered a Component Project Activity (CPA).

In Vietnam's legal context, while Decree 06/2022/ND-CP laid the initial groundwork, Decree 119/2025/ND-CP has further clarified the registration and implementation process for such "programmes" and "projects" under both domestic and international mechanisms, explicitly including those compliant with Article 6 of the Paris Agreement. The regulations for registering projects, as detailed in the amended decrees, apply to both individual projects and these larger programmes of activities.

The benefits for SMEs participating in this model are very clear, as it directly addresses their primary market entry barriers. Firstly, cost sharing dramatically reduces the financial burden that often prevents individual SMEs from accessing the carbon market; this is because the significant costs associated with technical consultancy, developing methodologies, and undergoing the entire validation and verification (the core of MRV) are shared among all participants. Secondly, the PoA offers simplified procedures. SMEs do not need to develop a complex Project Design Document (PDD) from scratch. Instead, they follow the pre-approved framework, methodologies, and monitoring plans already established by the CME, which significantly streamlines the registration process for each individual CPA. Finally, the model provides increased market attractiveness. By aggregating the emission reductions from multiple small projects, a PoA generates a larger, more consistent volume of carbon credits. This makes the credits more appealing and marketable to both domestic and international buyers, who often prefer to purchase in larger quantities.