Resolution 254/2025/QH15 — easing the 2024 Land Law bottlenecks
The National Assembly has passed Resolution 254/2025/QH15, setting out special mechanisms and policies to clear obstacles in carrying out the 2024 Land Law. This piece analyses its scope, term of effect, and the six groups of real-estate projects that benefit directly.
On 23 December 2025, the National Assembly passed Resolution 254/2025/QH15, setting out special mechanisms and policies to clear the obstacles that have arisen in implementing the 2024 Land Law — a statute in force for less than two years, yet one that has already exposed several bottlenecks that seriously stall the real-estate market and investment projects.
The Resolution has two notable features: first, it does not amend the Law itself but issues special mechanisms that apply in parallel; second, its scope is clearly confined to six specific groups of projects — avoiding the risk of over-broad application and prolonged legal conflict.
The six project groups granted special mechanisms
Under Article 3 of the Resolution, the following six groups of real-estate and investment projects will receive special mechanisms for three years from the date the Resolution takes effect:
| Group | Project type | Special mechanism |
|---|---|---|
| N1 | Commercial housing projects with an investment-policy approval issued before 01.01.2024 | Continue applying land prices under the old price schedule |
| N2 | Industrial-park projects whose master plan was approved before 01.07.2024 | One-off land allocation instead of annual allocation |
| N3 | PPP projects with obstacles over land-use fees | Settlement based on actual value |
| N4 | BT projects paid for with land funds | Apply Decree 256/2025/NĐ-CP as the guiding document |
| N5 | Resettlement projects funded by the state budget | Simplified appraisal procedures |
| N6 | FDI projects with land-valuation obstacles after extension | Permit re-valuation using the direct-comparison method |
Each project group will receive specific guidance from the Government within 90 days of the Resolution taking effect. For Group 4 in particular, BLF has published a detailed analysis of Decree 256/2025/NĐ-CP in the Highlight 10 · 2025 issue.
Resolution 254 is not a legal step backward — it is a commendable piece of legislative craft that keeps the 2024 Land Law stable while still letting the market move.— Trần Ninh Hà · Managing Partner, BLF
Term of effect and operational risks
The Resolution takes effect on 01 February 2026 and applies for three years. After three years, if the obstacles have been resolved through an amended Law, the special mechanisms will automatically lapse. If not, the National Assembly will consider extending them or elevating them into a Law amendment.
During this period, enterprises should pay particular attention to three operational risks: (1) the transitional rules between the old and new mechanisms for each project group; (2) the supplementary reporting that provincial Departments of Planning & Investment may require in the early application phase; and (3) the possibility that tax and finance authorities are slow to update guidance at the local level.
Reference materials
This article is compiled from official legal documents published in the Government Gazette and on the National Assembly's web portal:
- Resolution 254/2025/QH15 — National Assembly · 23.12.2025
- Land Law 31/2024/QH15 — National Assembly · 18.01.2024
- Decree 256/2025/NĐ-CP — Government · 03.10.2025
This article is a professional analysis by Business Law Firm and does not replace specific legal advice for individual matters. Clients are welcome to contact us directly for advice tailored to their situation.
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