HCMC TIGHTENS REAL ESTATE DATA MANAGEMENT: IMPLICATIONS FOR DEVELOPERS AND PROJECT DEVELOPMENT STRATEGIES

1. From Digital Reporting to Market Data Management

In 2026, HCMC has gradually rolled out its housing and real estate market information system and database, with a focus on centralization, standardization and improved connectivity between regulatory authorities and businesses.

In early March 2026, the city created and distributed more than 600 user accounts to government agencies, project developers, investors and real estate service businesses. This initial step enabled these entities to access the system and submit the required information. The figure represents the number of accounts distributed at that time; it should not be interpreted as the number of businesses that have fulfilled their reporting obligations.

In October 2026, the HCMC Department of Construction required project developers and real estate brokerage platforms to establish accounts linked to electronic identification for the purpose of reporting and disclosing project information. Individuals authorized by their respective businesses to use these accounts must log in to the system through VNeID using their registered identification credentials. This requirement aims to strengthen the authentication of information providers and facilitate data verification and cross-checking.

Notably, on November 4, 2026, the HCMC People's Committee issued Decision No. 95/2026/QD-UBND, which is scheduled to take effect on November 15, 2026. The decision sets out the coordination mechanism for developing, sharing and providing information on housing and the real estate market within the city.

Overall, the implementation process is progressing from the establishment of access infrastructure and the identification of information providers to the introduction of data update and sharing responsibilities.

2. Key Implementation Milestones and Regulatory Requirements

Several important figures and regulatory milestones deserve attention:

• More than 600 user accounts: Created and distributed in early March 2026. These accounts were allocated to various groups of users and do not represent the number of businesses that have completed their reporting obligations.

• November 15, 2026: The scheduled effective date of Decision No. 95/2026/QD-UBND.

• Real-time data updates: Apply to the categories of information and data specified under Article 30 of Decree No. 357/2025/ND-CP whenever relevant changes occur.

• Quarterly data submissions: For data categories used for periodic reporting and disclosure, information must be submitted before the 10th day of the first month of the following quarter, in accordance with applicable regulations.

Market-related information categories include project legal status, project scale and construction progress, the number of units sold, floor area, transaction value and unsold inventory. However, each data field must be cross-checked against the relevant regulations and reporting templates to determine its exact scope, applicable entities and submission deadlines.

Importantly, not every data field is subject to real-time updates. The applicable requirements depend on the specific data category and the corresponding provisions of Decree No. 357/2025/ND-CP and Decision No. 95/2026/QD-UBND.

3. From Information Updates to Real-Time Data Management

One notable development is that businesses must operate under two complementary data submission mechanisms: real-time updates when changes occur for applicable data categories, and quarterly submissions for the relevant periodic reporting categories.

In addition, project information is increasingly subject to authentication requirements and cross-checking against legal documentation. Depending on the project type and applicable requirements, relevant documents may include land allocation decisions, detailed planning documents, construction permits and official confirmations that housing units under construction are eligible for sale.

Data management responsibilities also require clear internal delegation within each business. The legal representative is responsible for assigning personnel to enter data and organizing the review and approval process to ensure that submitted information is accurate, truthful and timely in accordance with regulations.

This requires coordination among the legal, project development, sales, finance and operations departments, rather than assigning the entire process to administrative personnel.

4. Project Developers Facing Greater Transparency Requirements

4.1. First, standardizing legal documentation management.

Businesses need to manage project documentation throughout each stage of development, from land procedures and planning approvals to construction permits and eligibility for property sales. Each document should be monitored in terms of its issuance date, issuing authority, scope of application and validity status. This helps prevent the use of outdated documents or the disclosure of inconsistent information.

4.2. Second, linking sales data with cash flow.

The number of units sold, transaction value and unsold inventory are important indicators, but they are not equivalent to recognized revenue or cash actually collected. Project developers need to reconcile transaction data with contracts, payment schedules, outstanding receivables and accounting records to obtain an accurate picture of a project's financial position.

4.3. Third, monitoring project implementation progress.

Legal procedures, design, construction, disbursement and sales progress should be tracked separately while remaining interconnected. A project that is progressing well in terms of construction does not necessarily mean that all legal procedures have been completed. Standardized data enables businesses to identify inconsistencies at an early stage and proactively adjust their plans.

4.4. Fourth, accurately assessing market absorption.

Transaction data should be analyzed alongside actual selling prices, the conversion rate from booking to contract signing, payment progress, transaction cancellation rates and outstanding receivables. These internal management indicators help businesses assess market demand, sales performance and cash flow generation, rather than relying solely on the number of units transacted.

5. Key Implications for the Real Estate Market

The changes to data submission and disclosure mechanisms give rise to five important observations:

5.1. Data coverage is a decisive factor.

The distribution of more than 600 accounts reflects an initial implementation milestone, but does not demonstrate that the database covers the entire market. The system's effectiveness depends on the level of participation and the accuracy of information provided by participating entities.

5.2. Identification codes can improve data integration.

However, the management value of identification codes depends on their ability to accurately link project information, individual property units, legal documentation and transaction data. This is also an area that businesses need to prioritize when standardizing their internal data systems.

5.3. Greater transparency supports project risk assessment.

More accessible and traceable legal documentation provides additional information for buyers, banks and business partners when conducting due diligence. However, publicly available data does not replace the need for independent legal verification.

5.4. Transactions do not necessarily translate into cash flow.

The number of units sold and transaction value need to be reconciled with actual cash receipts, outstanding receivables and payment obligations to accurately reflect a project's financial health.

5.5. Data governance is becoming an internal business capability.

Clearly assigning responsibility for data creation, review, approval and accountability can reduce inconsistencies across departments while strengthening regulatory compliance.

6. Digital Data and the Long-Term Direction of Sustainable Market Development

Over the long term, the real estate database could bring about changes at three levels.

For regulatory authorities, standardized data can support the monitoring of property supply, project progress and legal status. For businesses, it creates an incentive to integrate legal, construction, sales and financial management into a unified information system. For the market, improved data traceability and cross-verification can help reduce information asymmetry among project developers, investors and property buyers.

However, the actual effectiveness of the system will depend on data completeness, accuracy and verifiability. Project developers should monitor indicators such as on-time data update rates, consistency between publicly disclosed information and original documentation, the ability to link identification codes, and the resolution of data discrepancies.

Conclusion

HCMC's efforts to strengthen real estate data management represent more than a change in reporting procedures; they introduce new requirements for project management capabilities. For project developers, standardizing legal, construction progress, property inventory and cash flow data will become increasingly important throughout project implementation and commercialization. Over the long term, businesses with transparent, consistent and verifiable data systems will be better positioned to strengthen their management capabilities in a market that places growing emphasis on information quality.