THE INCOME VERIFICATION PARADOX FOR INFORMAL WORKERS: WHAT BOTTLENECKS ARE HINDERING LIQUIDITY IN THE SOCIAL HOUSING MARKET?

1. Easing Income Requirements, but Implementation Pressures Remain

The legal framework governing eligibility for social housing (NOXH), including housing and income requirements, is set out in Articles 29 and 30 of Decree No. 100/2024/ND-CP, together with relevant amending and supplementary regulations. Adjustments to the income thresholds are intended to broaden access to housing for urban workers while strengthening mechanisms for self-declaration, undertakings, and post-verification.

However, determining income over the preceding 12 consecutive months can create difficulties for individuals who frequently move between formal and informal employment. For example, a person who spends six months working independently and six months employed by a company may need to complete documentation using different verification methods for each period. If coordination among the relevant parties is inconsistent, the processing of applications and the developer’s sales schedule may both be affected.

2. Income Thresholds That Determine Eligibility to Purchase Social Housing

Under Clause 1, Article 30 of Decree No. 100/2024/ND-CP, as amended and supplemented by Decree No. 136/2026/ND-CP, the average monthly actual income thresholds for determining eligibility to purchase social housing are VND 25 million for a single individual, VND 35 million for a single individual raising a minor child, and VND 50 million for a married couple’s combined income. Income is determined over the 12 consecutive months immediately preceding the date on which the competent authority carries out the verification.

These thresholds are an important basis for screening applications. However, satisfying the income requirement does not automatically mean that an application will be approved. Applicants must also meet other eligibility requirements and submit the documentation applicable to their particular circumstances.

3. The Boundary Between Income Verification by Employers and Commune-Level Police

3.1. What information do commune-level police verify?

The verification mechanism needs to clearly distinguish between personal information, residence information, and responsibility for income declarations. Commune-level police carry out verification within the scope prescribed by law, while applicants are responsible for the accuracy and truthfulness of their income declarations and undertakings and may be subject to verification or post-verification where necessary.

Accordingly, the verification of residence information should not be conflated with certification of a person’s entire cash income. Clearly allocating responsibilities helps prevent local authorities from being asked to perform tasks beyond their statutory authority.

3.2. How are applications involving mixed sources of income handled?

In a citizen Q&A published on July 22, 2026, the Government News website cited guidance from the Ministry of Construction concerning workers who have periods of unemployment or self-employment interspersed with periods of employment at a company:

“Commune-level police shall carry out verification for the periods during which the applicant declares that they were unemployed/self-employed, while the agency, organization, or enterprise where the applicant worked shall verify the income eligibility requirements for the periods during which the applicant was employed (with the total verification period covering the preceding 12 consecutive months).” Source: Government News, July 22, 2026.

This guidance indicates that an application is assessed by individual periods within the overall 12-month period, rather than requiring a single authority to verify the applicant’s entire employment history. For example, for a person who has six months of self-employment and six months of employment at a company, the documentation should be prepared based on the person’s employment status during each period and the corresponding verification requirements. It is important to distinguish between verification of the self-employment period and direct certification by commune-level police of the exact amount of income earned. The applicant remains responsible for providing information and making the required declarations and undertakings.

Therefore, the practical issue is not necessarily that the law completely fails to address cases involving mixed income sources. Rather, the key concern is consistency in guidance, application intake, and coordination among the relevant authorities in the verification process, so as to minimize repeated requests for additional documents and unnecessary delays in approval.

4. How Delays in Application Processing Can Affect Project Liquidity

4.1. Customer conversion rates may decline

Customers with fluctuating employment histories are a group that developers need to pay particular attention to when building a pool of prospective social housing buyers. When applications require additional documents or clarification of income information, the period from application submission to eligibility approval and the signing of the sale and purchase agreement may be extended.

For developers, delays in completing a large number of applications can affect the consolidation of the customer list and subsequent stages of the sales process. However, it is important to distinguish between an incomplete application and a customer who is ineligible to purchase social housing, as these two situations require different approaches.

4.2. Limited profit margins increase pressure on capital turnover

Given the mechanism limiting the developer’s profit margin on a social housing project to a maximum of 10%, effective cost control and the speed of capital recovery are important factors in determining the developer’s financial performance. If the completion of buyers’ applications is delayed, the verification of the eligible-buyer list and the timing of contract signing and scheduled payments may also be affected.

The actual impact will depend on factors such as construction progress, financing arrangements, payment schedules, and market demand. Nevertheless, for projects that rely on cash inflows from successive sales phases, reducing the time required to process applications is an important consideration in liquidity management.

4.3. Balancing compliance and processing speed

If developers accept applications without sufficient supporting evidence or interpret the regulations too flexibly, projects may face compliance risks when competent authorities inspect the list of eligible beneficiaries. Conversely, applying the rules mechanically or failing to update procedures in line with new guidance may unnecessarily delay applications from otherwise eligible customers.

The solution is therefore not simply to loosen or tighten the approval process, but to standardize eligibility criteria, clearly allocate verification responsibilities, and apply procedures consistently.

5. Three Key Issues Developers Should Keep in Mind

First, clearly allocate verification responsibilities. Commune-level police should carry out verification within the scope prescribed by law; employers should verify information relating to periods during which the applicant worked for the relevant organization or company; and applicants remain responsible for the accuracy of their declarations and undertakings as required by law.

Second, do not assume that applicants must have continuous payroll records covering the full 12 months. The 12-month period is the reference period for determining income eligibility; it does not mean that every applicant must have worked for the same company throughout those 12 months. Ministry of Construction guidance has addressed verification by individual periods for cases involving mixed sources of income.

Third, prioritize consistency in implementation. Clear operational guidance, appropriate forms, and consistent application-intake procedures can reduce the number of times applicants are required to supplement their documentation. This is an issue that should be assessed based on actual application processing practices at the local level, rather than assuming that every difficulty stems from a legal gap.

6. Data Digitization and Proactive Customer Screening

In the longer term, connecting identity data with personal income tax and social insurance databases could facilitate information cross-checking, reduce reliance on fragmented paper documents, and minimize the need for citizens to submit the same information repeatedly to different authorities. However, tax and social insurance data do not always fully capture the income of self-employed or informal workers. Therefore, digitization should be accompanied by mechanisms for self-declaration, undertakings, post-verification, and personal data protection.

At present, developers can proactively screen applications from the initial consultation stage by categorizing prospective buyers according to their employment histories, guiding them to prepare the appropriate supporting documents for each period within the 12-month reference period, and monitoring processing times at each stage. Where the applicable procedure remains unclear, developers can also submit a written request to the competent authority for operational guidance. This can help reduce compliance risks when implementing the process on a larger scale.

Conclusion

Raising the income ceiling expands opportunities to access social housing, but the effectiveness of the policy ultimately depends on the ability to convert demand into valid applications and completed transactions. For workers with mixed income sources, the legal framework already provides guidance on verification by individual periods. The key challenge is ensuring that these procedures are applied consistently and within the proper scope of authority. For developers, standardizing application requirements, proactively coordinating with relevant authorities, and effectively managing the approval timeline are important measures to minimize the risk of slower sales, protect cash flow, and maintain project liquidity.