A Comparative Legal Assessment of Renewable Energy Governance in Vietnam and China: A Five-Pillar Framework

Renewable energy transitions depend not only on capacity targets and financial incentives but also on coherent legal arrangements governing institutions, infrastructure, investment, environmental protection, and technological capability. This article develops a Five-Pillar Framework comprising Institutions and Policies, Infrastructure and Technology, Finance and Investment, Society and Environment, and Human Resources and Research and Development. It applies a comparative doctrinal and policy analysis to Vietnam and China, two state-led Asian economies with similar transition objectives but different regulatory maturity and implementation capacity. The assessment uses three cross-cutting criteria—legal certainty, institutional coherence, and implementation capacity—and is supplemented by a 2026 survey of 150 Vietnamese stakeholders from four professional groups. The findings show that China has a comparatively more consolidated statutory framework, coordinated grid planning, diversified financing instruments, and stronger domestic technological capacity, while also facing subsidy arrears, regional grid imbalances, and socio-environmental risks. Vietnam has modernized its electricity legislation, direct power purchase framework, and renewable-energy regulation, but implementation remains constrained by legislative dispersion, grid congestion, weak contractual risk allocation, and remaining limitations in the specificity and implementation of storage, social-impact, and innovation rules. China therefore offers a context-sensitive benchmark rather than a directly transferable model. The article proposes sequenced reforms for Vietnam, prioritizing regulatory continuity, bankable contracts, grid flexibility, social safeguards, legal coordination, and domestic innovation.