Clause 4, Article 5 of Decree 91/2019/ND-CP stipulates penalties for transferring red books without registering land changes as follows:
Forms of punishment, remedial measures
4. The application of administrative sanctions and remedial measures in case of transactions on land use rights are as follows:
a) In case of administrative violations occurring before the transfer of land use rights, the transferor of land use rights shall be administratively sanctioned and must take measures to force the return of illegal profits gained from the violation, and must restore the original state of the land before the violation (if the transfer of rights is sanctioned, the transferee must return the land to the transferor) according to regulations. The transferee of land use rights must take measures to remedy the remaining consequences for each violation according to regulations;
b) In case of land use right conversion without land change registration, both parties transferring land use right shall be administratively sanctioned. In case of transfer, inheritance, donation, capital contribution using land use right without land change registration, the party receiving the land use right transfer shall be administratively sanctioned. In case of leasing or mortgaging land use right without land change registration, the land user who leased or mortgaged the land shall be administratively sanctioned.
In addition to administrative sanctions as prescribed in this point, the transferor and transferee must also take remedial measures for each specific case as prescribed in this Decree.
Thus, in case of transferring the red book without registering land changes, the buyer (the party receiving the land use rights transfer) will be subject to administrative penalties according to regulations.