The 2025 Construction Law introduces a number of significant changes to the preparation, appraisal, and implementation of construction investment projects. For business investment projects, these changes not only concern administrative procedures but also directly affect investors’ authority, responsibilities, and project management capabilities.
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The 2025 Construction Law introduces a revised classification of projects based on their investment structure, including public investment projects, PPP projects, projects using recurrent state budget expenditures, and business investment projects.
Business investment projects are construction investment projects subject to investment legislation and other projects that do not fall into the separately regulated categories.
This classification provides a clearer basis for determining the applicable management mechanisms and responsibilities of the parties involved.
For the real estate sector, this is particularly relevant as many property development projects fall into the category of business investment projects.
One of the notable changes under the 2025 Construction Law is the clearer allocation of responsibilities during the appraisal and implementation of designs.
For business investment projects, the investment decision-maker is responsible for organizing project appraisal. The appraisal focuses on compliance with the investment policy, where applicable, the design brief, and the project’s technological design requirements.
Once the project has been approved, the investor is responsible for appraising, controlling, and approving the detailed construction design.
Investors are given greater autonomy in organizing project implementation, while at the same time being required to strengthen their capacity to control design, quality, and project risks.
In other words, Greater authority comes with greater responsibility.
The 2025 Construction Law reflects a clear shift from a multi-layered pre-control mechanism toward “single-stage control” with stronger post-control.
At the same time, certain appraisal procedures for detailed designs after project approval have been removed at specialized construction authorities, with greater responsibility placed on investors.
For project developers, this approach may help reduce overlapping administrative procedures. However, it does not mean that internal controls can be relaxed.
On the contrary, investors need robust systems to control:
Another change that can directly affect project implementation timelines is the expansion of cases eligible for construction permit exemptions for certain works that have already undergone the required appraisal.
The Law introduces the principle that: "Each construction work should only be subject to one administrative procedure from the project preparation stage through to construction commencement."
This includes additional cases where construction works are part of a project for which the feasibility study or adjusted feasibility study has been appraised by the competent construction authority and duly approved.
This change may help streamline the pre-construction process, particularly for projects that have already undergone appropriate controls during the investment preparation stage.
The 2025 Construction Law abolishes requirements concerning organizational capacity conditions and organizational capacity certificates for construction businesses.
Instead, organizations are responsible for publicly disclosing information about their construction capacity, while their legal representatives are responsible for the accuracy and truthfulness of the disclosed information.
This change reduces certain procedural requirements while simultaneously placing greater emphasis on actual capacity and corporate transparency.
For investors, selecting consultants, contractors, and partners based on their actual capabilities therefore becomes increasingly important.
Taken together, these changes reveal a consistent direction under the 2025 Construction Law:
Streamlined procedures → Greater autonomy → Greater responsibility.
The Law also provides clearer responsibilities for different stakeholders: state management agencies focus on developing management platforms, information systems, and national databases; investors take primary responsibility for organizing project management and appraising detailed construction designs; while contractors are required to maintain professional independence and refuse unlawful requests.
This places greater demands on investors to establish effective project management systems capable of proactively controlling the entire development process.
The impact of the 2025 Construction Law on investors and business investment projects can be summarized in four key areas:
| Change | Impact |
|---|---|
| Clearer project classification | Provides a clearer basis for management mechanisms according to the investment structure |
| Greater investor autonomy | Investors have greater control over the appraisal, control, and approval of detailed designs |
| Streamlined procedures | Reduces overlapping control procedures and expands construction permit exemptions |
| Greater responsibility | Requires stronger project management, quality control, and legal compliance capabilities |
The most important aspect of the 2025 Construction Law is not simply how many procedures have been eliminated, but rather the change in how responsibilities are allocated.
As pre-control mechanisms are streamlined and greater autonomy is given to investors, project management capabilities become a critical factor in turning greater autonomy into practical efficiency.
For project developers, this creates an increasingly clear requirement: not only to develop projects in compliance with the law, but also to effectively manage design, quality, schedules, and risks throughout the project lifecycle.
In this context, proactively keeping up with regulatory changes and building integrated project management capabilities will be an important foundation for businesses to adapt to the new management approach and pursue sustainable project development.