However, for this regulation to be feasible, it is necessary to clarify concepts, simplify procedures and build a shared databse, rather than forcing businesses to shoulder additional compliance costs.

Article 10 is one of the most notable contents of the draft circular because it directly affects how businesses publish, adjust and declare retail fuel prices in the market. In principle, increasing transparency requirements is necessary. 

The more transparent the fuel market is, the more it can limit suspicion, reduce distortions in distribution and provide stronger grounds for regulators to supervise.

However, the problem is that Article 10 currently combines several requirements without clarifying them. Price publication, price adjustment and price declaration are three different stages. Publishing prices means releasing information to the market. Adjusting prices means changing the selling price. Declaring prices refers to the obligation to report to state management agencies.

If these three concepts are not defined and guided very clearly, businesses will easily be confused during implementation, and each locality might interpret them in a different way. A good policy must not be only correct in its goal but also clear in its interpretation. With a sensitive commodity like fuel, even a small point of ambiguity in the regulations can create inconsistent application, increasing risks for businesses and reducing management effectiveness.

Transparency doesn’t mean additional procedures

The next point to note is the sequence and timing of implementation. Do businesses have to declare before or after applying new prices? Within how long must it be completed? If the software system encounters a malfunction, how is it handled? These are very practical questions, yet they directly decide the feasibility of the policy. 

Fuel is a commodity that moves according to market performance, requiring fast processing speeds. If regulations are unclear, businesses will fall into a situation where they want to comply regulations but do not know how to do it correctly. At that time, the transparency goal might unintentionally be turned into a procedural burden.

Article 10 should be designed so that businesses are allowed to announce and apply prices according to the current mechanism, while simultaneously completing electronic declaration obligations within a specific timeframe, clear enough to implement but not hindering the circulation of goods. 

Along with that, there must be a backup mechanism in case the technical system encounters an incident, avoiding a situation where a technical error disrupts business activities.

Another very important thing is to avoid a situation where businesses have to send the same data to many different agencies. If they have to send reports to the Ministry of Industry and Trade (MOIT), the provincial People's Committee and other agencies, compliance costs will increase, while management efficiency may not increase correspondingly. The current spirit of reform must be that businesses declare once on a digital platform, and management agencies jointly exploit the data according to their authority.

Data transparency 

Article 10 would have much greater significance if it goes beyond internal declarations and moves toward public disclosure of retail price data in a way that is easy to access and monitor. The fuel market has long had many regulations, but it still lacks a sufficiently clear information disclosure mechanism for citizens, businesses and society to follow.

Therefore, alongside declaration requirements, a centralized database on retail fuel prices should be established, allowing users to search by company, region, time and type of fuel. When information is publicly available, the market becomes more transparent, healthy competitive pressure increases and regulators gain real-time monitoring tools.

Similarly, regulations on pricing methods and principles should also be more specific. It is not enough to require businesses to announce general principles without specifying minimum information that must be disclosed.

It is necessary to clarify which costs are included in the price, what the principles for allocating transport costs are, and on what basis the differences between regions are based. When the basic components are transparent, the market will operate more convincingly and social trust will be consolidated.

Dr Ngo Tri Long