The legal framework governing tourism real estate is gradually being refined, laying the groundwork for resolving long-standing market bottlenecks. However, the current supply of tourist apartments remains insufficient to meet growing accommodation demand.
Speaking at a conference titled “Tourism real estate in a new cycle: From legal frameworks to operational value” on Friday, Chu Van Hai, deputy chief of the Central Steering Committee Office for Housing Policy and Real Estate Market, said the legal framework for tourism real estate had evolved through three distinct phases.
Legal framework improves, easing market bottlenecks
Before 2020, there were no specific land or real estate business regulations governing tourist apartments and villas. From 2020 to July 2024, the government’s Decree 10/2023/ND-CP provided a basis for issuing ownership certificates for tourist accommodation facilities built on commercial and service land.
Since August 1, 2024, the 2023 Law on Real Estate Business and the 2024 Land Law have introduced additional provisions governing tourism and accommodation facilities, business activities and the issuance of ownership certificates, gradually addressing legal obstacles.
Chu Van Hai, deputy chief of the Central Steering Committee Office for Housing Policy and Real Estate Market, speaks at a conference on tourism real estate on October 30, 2026. Photo courtesy of the event organizers.
Tourism real estate is currently governed by five groups of legislation: investment, land, construction, real estate business and tourism.
Notably, Hai said amendments to the Land Law, Housing Law and Law on Real Estate Business were being submitted to the National Assembly for consideration and approval.
Among the proposed changes are new provisions on the transfer of sale and lease-purchase contracts for floor areas in properties that are either under construction or already completed but have yet to receive ownership certificates under land legislation.
Regarding extensions of ownership periods, properties whose ownership terms have expired may be considered for an extension, subject to the fulfilment of financial obligations under housing, land and other relevant laws.
On ownership certification, for real estate developed under projects for sale or lease-purchase, certificates will be issued to buyers or lease-purchasers rather than project developers. Exceptions apply where developers already hold certificates of land-use rights and ownership of assets attached to land, or wish to obtain certificates for properties that have not yet been sold or leased.
Another notable change concerns tighter controls over the terms of real estate business contracts. Under the proposed rules, developers would be prohibited from including clauses that limit or exclude their liability to customers, restrict customers’ rights to lodge complaints or initiate legal proceedings, or violate the principle of good faith under civil law. Such provisions must also not create an imbalance in contractual rights and obligations to the detriment of customers.
“The legal framework for tourism real estate is now clear. The coordinated amendments to the Land Law, Housing Law and Law on Real Estate Business at this National Assembly session will help the sector enter a new development cycle. This will improve accommodation infrastructure and support the goal of making tourism a key economic sector,” Hai said.
Sharing this view, Le Dang Tuan, deputy director of the Gia Lai provincial Department of Construction, said condotel-related issues had previously been complicated, but relevant legal provisions had become relatively clear since 2017. “This is an important step towards removing bottlenecks and building confidence among secondary investors to invest in these products,” he said.
More than 15 tourism and resort real estate projects have been or are being developed in the eastern part of the central province of Gia Lai, with an expected supply of over 9,000 resort apartments and villas.
However, challenges remain as there are no specific regulations governing the management and operation of condotel buildings comparable to those applicable to residential apartment buildings. This has led to disputes between developers and secondary investors over management and operating costs, including electricity, water, cleaning and parking, as well as maintenance, repairs and security.
Meanwhile, Tran Du Lich, vice chairman of the Vietnam International Arbitration Centre (VIAC), said tourism real estate had distinct characteristics that set it apart from conventional real estate.
Investors therefore need to change their mindset and view this property segment as an integral part of the broader tourism ecosystem and market.
Tran Du Lich, vice chairman of the Vietnam International Arbitration Centre (VIAC). Photo courtesy of the conference organizers.
According to Lich, resort real estate cannot generate substantial value without a developed tourism market and a complete service ecosystem. Operational performance depends on the characteristics of each destination, its ability to attract visitors, and the quality of management and operations.
On the legal front, Lich noted that tourism real estate was governed by multiple laws, including the Land Law, Construction Law, Housing Law and Law on Real Estate Business. He expressed hope that the latest round of legislative amendments would make regulations clearer and establish more distinct legal boundaries.
Tourist apartment supply falls short of demand
Alongside the legal framework, supply and demand dynamics and operational efficiency are also key issues facing the tourism real estate market.
Nguyen Van Dinh, vice chairman of the Vietnam Association of Realtors and chairman of the Vietnam Association of Real Estate Brokers (VARS), said Vietnam had a total of 146,438 tourist apartment units, serving accommodation demand from nearly 70 million visitors annually.
This supply was insufficient to meet even half of actual demand and remained well below the targets set out in the Politburo’s Resolution 26-NQ/TW, he said.
Dinh said Vietnam had abundant natural resources for tourism development, spread across various regions, from highlands and border areas to deltas and coastal zones. However, these resources were still being exploited in a fragmented manner, with limited regional connectivity and much of their potential untapped.
In addition, infrastructure quality at many tourist destinations remained inadequate, while their economic performance was still limited.
A positive trend has emerged in several localities that have become bright spots by improving tourism quality and developing large-scale tourism urban complexes ranging from several hundred to thousands of hectares.
“In these urban complexes, residents participate in building professional, efficient and sustainable tourism service ecosystems. Many tourist destinations have invested in integrated infrastructure and services under an all-in-one model, helping attract visitors and encourage longer stays,” Dinh said.
InterContinental Phu Quoc Long Beach, one of the leading resorts in Phu Quoc island, southern Vietnam. Photo courtesy of InterContinental.
Looking ahead to 2030, Dinh forecast strong and stable economic growth, continued government support for investment and business activities in tourism real estate, and improvements in economic infrastructure, services and regional connectivity. These factors are expected to drive a sharp increase in both domestic and international tourist arrivals.
The secondary market for tourist apartments, shophouses and villas is forecast to recover in 2028 as tourism growth accelerates. These property types could become a major source of supply for high-end accommodation infrastructure.
Assessing potential customer segments and demand for tourist apartments, Dinh estimated that international arrivals could reach 30 million to 40 million, while the number of high-end domestic tourist trips could reach around 160 million annually. The current supply of tourist apartments meets only about one-third of demand, he said.
From a business perspective, Ricky Ho, regional general manager of FLC Quy Nhon, said Vietnam’s condotel market had enormous potential, but a shift in approach was needed to unlock its value.
Condotel development should not be viewed as a short-term investment but rather as part of a broader, long-term national destination development strategy, supported by robust infrastructure, clear planning and a transparent legal framework.
Nguyen Minh Phong, an economist and member of the Economic Advisory Council of the Vietnam Fatherland Front Central Committee for the 2026-2031 term, recommended that the government continue improving institutions, creating favorable conditions and prioritizing the allocation of prime land for tourism and resort real estate development. He also called for a comprehensive set of measures to ensure a balanced protection of the interests of all parties involved.
For businesses, Phong said developers needed to strengthen their financial capacity to maintain credibility and abandon unrealistic profit guarantees made in the past. They should also diversify their products and adopt more flexible management models, including developing options for customers who wish to operate their properties independently as businesses.