RESOLUTION 353/NQ-CP AND ITS IMPACT ON THE REAL ESTATE MARKET AND DEVELOPMENT STRATEGIES IN 2026

1. Inventory Pressure and Credit Quality

Resolution 353/NQ-CP assigns the Ministry of Construction to take the lead, in coordination with relevant ministries, agencies, and local authorities, in reporting to the Prime Minister in November 2026 on the overall state of the real estate market. The review will focus on supply, liquidity, prices, transactions, and inventory across different segments and localities, while also assessing supply and demand for social housing and rental housing in each locality.

The State Bank of Vietnam (SBV) is required to strengthen inspection and supervision of lending to potentially high-risk sectors, particularly real estate business lending. This includes monitoring outstanding credit, borrowers’ ability to meet upcoming debt obligations, and the financial position of enterprises undergoing debt restructuring. The focus is on resolving existing non-performing loans and preventing new ones from arising. The Resolution also calls for action against “backyard” arrangements, cross-ownership, undisclosed ownership structures, and the manipulation or undue influence over banking operations, in accordance with the law.

Market indicators point to mounting pressure on the market’s ability to absorb available supply. In the first nine months of 2026, Vietnam recorded approximately 331,876 successful real estate transactions, comprising 80,269 apartment and private-house transactions and 251,607 land plot transactions. In the third quarter alone, approximately 92,004 transactions were recorded, down 8% quarter-on-quarter. Apartment and private-house transactions reached 22,847, down 14%, while land plot transactions totaled 69,157, down 6%.

Meanwhile, reported inventory at real estate projects reached approximately 51,950 units and plots in Q3 2026, based on reports from 27 out of 34 provinces and centrally governed cities. Land plot inventory increased by 75.3% compared with Q2. These figures represent inventory reported by project developers and do not fully capture unfinished investment capital tied up in projects or difficulties in secondary-market transactions.

Notably, outstanding real estate credit stood at approximately VND 5.23 quadrillion as of the end of August 2026, accounting for more than 25% of total outstanding credit across the economy. The substantial scale of lending, amid declining transaction volumes, underscores the need for closer monitoring of loan quality, debt repayment capacity, and the overall safety of capital flows into the real estate sector.

2. Key Figures Shaping Vietnam’s Real Estate Market

Note: The reported inventory of 51,950 units and plots was compiled from reports submitted by 27 out of 34 localities and reflects inventory reported by project developers. In addition to the three categories listed above, the report recorded approximately 1,046 unsold units in tourism and resort developments, as well as office buildings combined with accommodation facilities. These were reported separately and are not included in the total of 51,950 units and plots.

For social housing, the preferential credit program under Resolution 33/NQ-CP has been expanded from VND 120 trillion to more than VND 153 trillion, with 11 commercial banks participating. As of August 31, 2026, total loan commitments reached approximately VND 50.3 trillion, while cumulative disbursements amounted to approximately VND 17.5 trillion. Of this amount, VND 15 trillion was disbursed to project developers and VND 2.5 trillion to homebuyers.

For homebuyers under the age of 35 purchasing social housing, cumulative disbursements amounted to approximately VND 577 billion, while outstanding loans stood at approximately VND 531 billion. These two indicators should be distinguished: cumulative disbursements represent the total amount of credit disbursed over the reporting period, whereas outstanding loans refer to the amount remaining on the books at the reporting date.

The gap between the program’s overall scale, committed lending, and actual disbursements indicates that expanding credit availability does not necessarily translate into equivalent access to financing for developers and homebuyers. Borrower eligibility, the availability of qualified projects, and homebuyers’ affordability remain key factors.

Data sources: Ministry of Construction, State Bank of Vietnam, and published information on the implementation of the social housing credit program.

3. Key Shifts in Policy and Market Regulation

Three major developments stand out in the Government’s regulatory approach.

First, the Government is strengthening market assessments by segment and locality. The Ministry of Construction has been tasked with reviewing supply, liquidity, prices, transactions, and inventory, while also assessing supply and demand for social housing and rental housing in each locality. This approach is expected to provide a clearer picture of regional market differences and potential mismatches between actual demand and available supply.

Second, credit quality is being tightened while priority sectors continue to receive support. The SBV is required to monitor outstanding loans, borrowers’ ability to meet upcoming debt obligations, and the debt restructuring status of real estate enterprises. Efforts will focus on resolving NPLs and preventing further deterioration in loan quality. At the same time, policy continues to support access to credit for businesses and individuals, particularly through lending programs for social housing and rental housing.

Third, greater transparency in ownership structures and banking governance is being emphasized. Measures targeting “backyard” arrangements, cross-ownership, undisclosed ownership structures, and the manipulation or undue influence over banking operations point to higher expectations for corporate governance, related-party transaction controls, and ownership transparency.

Alongside tighter risk management, social housing credit policies remain in place, including programs supporting homebuyers under the age of 35.

4. Implications for Project Development Strategies

For real estate developers, changes in the regulatory and credit environment call for more rigorous reviews throughout project research, investment, development, and operations.

4.1. Market and product positioning

Prioritize analysis of genuine housing demand, purchasing power, and absorption rates across individual segments rather than relying solely on expectations of price appreciation.

4.2. Legal compliance and project progress

Projects with clear legal documentation, sufficient conditions for implementation, and well-controlled construction schedules may be better positioned to secure financing while reducing the risk of additional costs arising from delays.

4.3. Financial management and cash flow

Review borrowing ratios, debt repayment schedules, financing costs, and actual cash receipts from sales. Recognized revenue or the value of signed contracts should not be mistaken for cash actually collected.

4.5. Corporate governance

Ensure transparency in ownership structures, capital contributions, internal transactions, and financial obligations between related legal entities.

4.5. Social housing development

Assess land availability, legal status, investment costs, selling prices, and homebuyers’ borrowing capacity together. An expansion of credit programs does not automatically translate into a corresponding increase in purchasing power.

5. Strategic Priorities for Real Estate Developers

Based on market data and regulatory developments, five key issues warrant particular attention:

5.1. Access to capital is not the only challenge

Rising project inventory alongside declining transaction volumes highlights the importance of assessing market absorption when making investment decisions.

5.2. Real estate risks are closely linked to the banking system

With outstanding real estate credit reaching VND 5.23 quadrillion, the quality of corporate cash flows and borrowers’ debt repayment capacity have become critical factors to monitor.

5.3. Ownership transparency is increasingly important

Capital structures, relationships between legal entities, and related-party transactions need to be clearly disclosed and effectively controlled.

5.4. Social housing financing still faces a gap between program scale and actual disbursement

Cumulative disbursements of VND 577 billion to homebuyers under the age of 35 highlight the need to address barriers to connecting eligible housing supply with prospective buyers who have both the need and the financial capacity to borrow.

5.5. Project development must reflect local market demand

Planning, infrastructure, legal status, available supply, and affordability should be assessed together from the initial investment research stage.

6. Market Outlook for the Coming Period

Over the longer term, Vietnam’s real estate market may enter a phase in which development quality takes precedence over investment expansion. Financial strength, legal transparency, cost control, and the ability to generate sustainable cash flow will be important factors for project developers.

Developers should consider shifting away from strategies centered primarily on accumulating land banks and expanding project portfolios toward selecting projects that are feasible to implement, aligned with market demand, and supported by viable financial plans. At the same time, monitoring actual transaction volumes, sales absorption rates, inventory levels, legal progress, outstanding debt, and repayment obligations should become an integral part of regular business management.

Conclusion

Resolution 353/NQ-CP reflects the Government’s direction toward strengthening oversight of real estate lending, controlling non-performing loans, improving transparency in banking operations, and conducting more comprehensive assessments of housing supply and demand.

For real estate developers, competitive advantage in the coming period will depend not only on land banks or investment scale, but also on the ability to secure legal approvals, execute projects effectively, and manage cash flow. In the long run, projects that address genuine market demand, maintain sound financial structures, and demonstrate clear implementation capacity are better positioned to achieve sustainable growth.