The salary table of the entire company cannot be conveniently provided
As Lao Dong reported that many people submitted documents at the CT3 Kim Chung social housing project (Tien Loc commune, Hanoi) reflecting the situation where the investor requested unreasonable additional documents.
Accordingly, in the case where employees have labor contracts, receive salaries in cash and have a salary table confirmed by the company, the investor of the CT3 Kim Chung social housing project still requires the whole company to submit the salary statement table.
Talking to reporters, Mr. Pham Duc Toan - General Director of EZ Vietnam Real Estate Investment and Development Joint Stock Company - said that the investor's request to declare the salary table of the entire company is a sensitive request, even violating the business secrets of the enterprise.
"The regulations on conditions and procedures for purchasing social housing have provided very clear instructions. Requiring people to provide salary tables for the entire agency is against regulations and causes difficulties. This is like a "sub-license" that the law does not require" - Mr. Toan emphasized.
The company representative said that no company would accept the disclosure of the entire salary table to an outside unit, unless there was a mandatory request from the police or a competent state agency.
That is confidential information of the business. Even at our unit, there is absolutely no such thing as providing the entire company's salary table to employees, because this requirement is completely unreasonable" - Mr. Toan said.
According to Mr. Toan, in the context of the State promoting administrative procedure reform, investors self- placeing additional "sub-licenses" is an act that needs to be corrected.
No regulations
Previously, in an interview with Lao Dong, Mr. Nguyen Thanh Trung - Director of the Project Management Board, representative of the handico & Viglacera Investor consortium - affirmed that the investor followed State regulations.
Citing, Mr. Trung said that in Section 9, form 04 of Circular 05/2024 and Section 9, form 01a of Circular 32/2025, both clearly stated: Photo: Salary table/oaires for the 12 consecutive months up to the time of confirmation by the competent authority.
"The investor is asking the authorities about solutions for the people" - Mr. Trung said.
However, when comparing legal regulations, there is currently no regulation requiring people to make a statement of the salary table of the entire company as proof when submitting documents to buy social housing.
Lawyer Nguyen Hong Tam - Director of Chi Cong & Thien Tam Law Firm LLC - said that social housing is a policy of our Party and State to support workers with housing difficulties. To put the policy into practice, the law must be adjusted in a more convenient direction in procedures and more widely on the subjects eligible to rent, buy, and lease social housing as prescribed in Article 78 of the Housing Law 2023, Article 30 of Decree 100/2024/ND-CP, amended by Decree 261/2025/ND-CP.
Investors who are the direct units of social housing projects must absolutely comply with legal regulations so that the subjects enjoy policies to ensure their rights, especially strictly prohibiting harassment, obstruction or unreasonable requirements.
For the salary statement table to prove income issued by the organization or unit to their employees, they must be directly responsible for the document issued by them before the law, the investor's request to issue a salary table for all personnel of that organization or unit is unfounded and not stipulated in any legal document.
At the same time, this also poses a potential risk of leaking information and personal data, affecting business operations and information security of other organizations, individuals and units.
"I affirm that buyers, renters, and tenants of social housing only have to submit registration documents according to the components and forms prescribed by law" - Lawyer Nguyen Hong Tam emphasized.
Specifically, Pursuant to Clause 1, Article 38 of Decree 100/2024/ND-CP, those who need to submit the dossier to the investor. The dossier recipient must record a receipt, if the dossier is not valid, the dossier recipient is responsible for clearly stating the reason for not being resolved and returning it to the dossier submitter for supplementation and completion.
If all other documents and requirements are not regulated, the dossier submitter has the right to refuse and request the investor to explain his/her requirements. In case of continued difficulties, home buyers can exercise their right to complain and report to competent authorities about the investor's violation.
In the context of promoting the reduction of procedures for social housing, lawyer Nguyen Hong Tam recommends drastic reform of administrative procedures and simplifying documents to make it easier for beneficiaries of this policy to access buying, renting, and leasing social housing.
On the other hand, there needs to be a digital transformation plan, receiving documents online to make public and transparent the submission of social housing registration, lease-purchase, and lease-purchase documents. In addition, inspection to ensure the right subjects for buying social housing also needs to be stepped up, if the wrong subjects are found, they must be strictly handled. Only then can social housing policies avoid the risk of exploitation and profiteering.
The CT3 Building Project belongs to the investment project to build a Social Housing Area in the Kim Chung New Urban Area, invested by the Joint Venture of Hanoi Housing Investment and Development Corporation and Viglacera Corporation - JSC. Open to receive the first phase of application from November 17, 2025 to January 3, 2026.
The total number of apartments in CT3 building is 1,104, including 929 social housing units and 175 commercial apartments. The provisional selling price of social housing apartments (including VAT and maintenance fees) is VND 18,400,000/m2.
