Ho Chi Minh City Real Estate Association (HoREA) has just issued document No. 110/2026/CV-HoREA dated September 3, 2026 proposing to supplement and unify regulations for real estate groups that are construction works with functions serving office, tourism, and accommodation purposes in the draft revised Real Estate Business Law.
The Ho Chi Minh City Real Estate Association (HoREA) realizes that investment and business activities of real estate products that are "construction works with functions serving office, tourism, and accommodation purposes" began to develop in our country from when the 2006 Real Estate Business Law took effect and developed very strongly in the "explosion" period of 2015-2019.
However, the 2014 Real Estate Business Law, the 2023 Real Estate Business Law and the draft revised Real Estate Business Law (hereinafter referred to as the draft Law) still do not have enough necessary regulations to comprehensively regulate investment and business activities of real estate products that are "construction works with functions serving office, tourism, and accommodation purposes".
Citing data from the Vietnam Association of Realtors, HoREA said that from 2022 to June 2026, 35,538 "condotels" were developed, including 24,767 tourist apartments, 10,771 tourist villas, and tourist townhouses. Including the previously formed supply, the total number of products belonging to this group is about 146,438, not including more than 10,000 officetels in Hanoi and Ho Chi Minh City.
In which, most "condotel" projects invested in the period 2007-2020 are "stuck" due to not having enough legal regulations to regulate or due to limitations of some localities in "law enforcement".
This leads to violations of the law when issuing Certificates of right to use "long-term stable residential land without forming residential units" for "condotels" built on "commercial service land", belonging to land use types with a maximum term of 50 years; or due to investors lacking capacity, violating the law, "committing too high profits" exceeding their ability to pay or mobilize capital when the project does not meet the conditions. These cases have been concluded and handled for violations by competent authorities and are "removing obstacles and difficulties for prolonged backlog projects.
The Association emphasized that completing the legal framework does not mean legalizing projects or arising violations. At the same time, it requires project investors to fulfill financial obligations to the State to unlock land resources, create conditions to restart projects, and ensure the legitimate and lawful rights and interests of customers and investors.
According to HoREA, the development of real estate types "with functions serving tourism and accommodation purposes", including "condotels", needs to be fully, synchronously, and uniformly regulated in the "draft Law on Real Estate Business (amended)" and related laws. This is to ensure the effectiveness and efficiency of state management, ensure harmony of interests of customers, investors, project investors and sustainable development.
