The Ministry of Agriculture and Environment received a petition from voters in Da Nang city with the content: According to Clause 1, Article 218 of the 2024 Land Law, many types of land such as: agricultural land, land used for public purposes, residential land, water surface land, religious land... can be used in combination with commercial and service purposes.
However, at point a, clause 2, Article 99 of Decree No. 102/2024/ND-CP dated July 30, 2024 of the Government, it is stipulated: "Using land for combined purposes does not fall into the case of having to change the land use purpose specified in Article 121 of the Land Law".
This regulation, when applied in practice, has caused obstacles in the implementation of multi-purpose land use mechanisms, especially for agricultural land interspersed in residential areas or areas with potential for commercial, service, and tourism development.
Voters proposed that the Ministry of Agriculture and Environment soon issue specific guidelines, expand the scope of applying the multi-purpose land use mechanism, in order to create conditions for localities to effectively exploit land funds, in accordance with socio-economic development practices.
Regarding this proposal, the Ministry of Agriculture and Environment has the following opinions:
Clause 2, Article 218 of the 2024 Land Law stipulates that the use of multi-purpose land must meet the requirement not to change the type of land according to the land classification specified in Clauses 2 and 3, Article 9 and has been determined in the types of documents specified in Article 10 of the Land Law. Clause 11, Article 3 of the Land Law stipulates that changing the land use purpose is the land user being allowed to change from this land use purpose to another land use purpose according to the provisions of the Land Law.
These are two different orders and procedures that have been specifically regulated by the Government in Decree No. 102/2024/ND-CP dated July 30, 2024, Decree No. 151/2025/ND-CP dated June 12, 2025 and Decree No. 226/2025/ND-CP dated August 15, 2025.
At the same time, recording voters' opinions, Clause 4, Article 11 of Resolution No. 254/2025/QH15 of the National Assembly stipulating a number of mechanisms and policies to remove difficulties and obstacles in the organization of the implementation of the Land Law has supplemented regulations assigning the Government to regulate cases of land use combined with other multi-purpose land.
Thus, the provisions of the law on land in the use of residential land plots or land plots with residential land and other land are increasingly being perfected in the direction of diversifying forms, improving land use efficiency.
