The Ho Chi Minh City Real Estate Association (HoREA) recently submitted comments to the Prime Minister and relevant ministries and branches on the draft Resolution on piloting the model "Real estate transaction center and land use rights established by the State".
After studying the draft's content in depth, HoREA determined that the proposal to establish a real estate transaction center at the present time is not really necessary, and at the same time pointed out many potential shortcomings if this model is implemented.

According to HoREA, the goal set by the Ministry of Construction in the draft is to build a model to help people and businesses carry out real estate transaction procedures in an electronic environment, increasing transparency and management efficiency.
However, the content of the remaining provisions of the draft does not clearly demonstrate the nature of "electronic transactions", but tends to form an additional administrative unit under the provincial People's Committee. This, according to the Association, risks creating new organizations, increasing staff, increasing budget expenditures, contrary to the policy of streamlining the state apparatus that has been concluded by the Central Government in the past.
HoREA also analyzed that many functions assigned by the draft to the Real Estate Transaction Center have already been implemented by state agencies. For example, receiving tax records under the Tax authority; receiving records for granting land use right certificates under the Land Registration Office; checking the conditions for selling future housing is the function of the Department of Construction. Therefore, if more Transaction Centers are established, it is easy to overlap functions, prolong procedures and waste resources.
In the context that Decree 118/2025/ND-CP clearly stipulates the mechanism of one-stop, one-stop connections, HoREA believes that the establishment of an additional intermediary unit is not appropriate.
In addition, HoREA said that the draft has not fully assessed the current real estate trading ecosystem. The market currently has a real estate trading floor, notary - certified system, brokerage units, legal consulting and a mechanism for publicizing investor information according to the Law on Real Estate Business 2023.
If these institutions are operated in accordance with regulations, it will be enough to ensure transparency. The addition of an State Transaction Center could reduce the role of the market and not completely solve core problems.
Instead of establishing a new model, HoREA proposes that the Government focus on perfecting the current legal framework, especially the obligation of investors to disclose information.
The Association emphasizes the need to supplement regulations requiring investors before selling future housing, available housing or land use rights in projects to fully and accurately announce product information on the Housing and Real Estate Market Information System and on local information portals. This is a core solution to help the market become transparent without the need to expand the administrative apparatus.
HoREA also noted a series of legal gaps that are causing risks to the market but have not been resolved in the draft, such as: subdivision and sale of land outside the project; the situation of collecting "deposit - reserve" money when the real estate is not qualified for business; lack of condotel and tourism real estate management mechanism; There are no regulations for the capital mobilization model in the form of "reducing real estate"; or the development of derivative real estate products and the type of "vacation ownership". According to the Association, these are urgent issues that need to be legalized soon.
Therefore, HoREA recommends that the Government should not pilot the Real Estate Transaction Center model at the present time. Instead, it is necessary to focus on developing a project to amend the Law on Real Estate Business and related laws to submit to the National Assembly in 2026, in order to create a more transparent, healthy and modern legal framework for the real estate market.
According to HoREA, the biggest goal is to protect consumer rights, enhance investor responsibility, and enhance the effectiveness of state management without having to establish new agencies.
Previously, at the seminar organized by Lao Dong Newspaper on October 22, 2025, experts said that the establishment of a State-managed Real Estate and Land Use Rights Trading Center is a necessary step to make transaction activities transparent, shorten procedures and reduce legal risks for people and businesses.
Lawyer Pham Thanh Tuan - real estate legal expert - said that the establishment of a real estate transaction center and land use rights managed by the State is necessary. This center (basically will be similar to the Stock Exchange) will help people and businesses perform transaction steps interconnectively from looking up information, establishing contracts, paying taxes, to issuing Certificates on a unified system. This model will contribute to improving the efficiency of state management, ensuring publicity, transparency and reducing transaction risks.
Mr. Nguyen Quoc Khanh - Vice President of the Vietnam Association of Realtors (VARS) - said that the establishment of a State-managed Real Estate Transaction and Land Use Rights Center is especially important in the process of transparency of the Vietnamese real estate market.
"The establishment of a trading floor has a very important purpose of promoting transparency in the real estate market, including the aspect of state management (issuing certificates, converting documents) and the aspect of products of investors".