“It is very difficult, and even not feasible, to confirm whether the communal/ward level has sufficient capacity to undertake land registration and data management tasks. If the tasks are assigned to communes or wards, the infrastructure investment cost for 3,321 communes/wards would be enormous,” says Pham Viet Thuan, director of the Institute of Natural Resources and Environment Economics in HCMC.

The decentralization of authority must be based on law and practical capacity. With land records involving large asset values, if wards/communes process them without proper authority, determining responsibility will be extremely complicated because, under the law, this function belongs to the provincial land registration office (LROs).

Regarding the proposal to shift LRO (land resource office) branches to the ward/commune level to make land procedures more convenient for citizens, Thuan discussed the issue with VietNamNet.

Could you please share your view on the proposal to decentralize and move LROs to the ward/commune level?

We are operating a two-tier local government model. Rearranging the provincial LROs is inevitable, and many localities have reorganized them into regional branch models.

However, in my opinion, we must clearly separate two functions. First, land resource technical management functions such as registration, title issuance, surveying, data updates, must remain under the provincial LROs.

Second, State management functions such as land allocation, land leasing, site clearance, and land-use conversion can be assigned to wards/communes.

Which legal documents currently regulate the functions of LROs? If we want to shift land registration duties to wards/communes, what legal changes are required?

The functions and duties of LROs are stipulated in the Land Law and detailed in Article 13 of Decree 102/2024. LRO is a provincial public service unit responsible for land registration; issuance, correction and revocation of land-use right certificates; surveying and cadastral mapping; managing cadastral records; operating land information systems; compiling land statistics and inventory; registering secured transactions; and providing public land services.

The decree also specifies tasks such as registration and updates of land changes; title issuance; survey checks; data updates; information provision; fee collection; and personnel and financial management.

If land registration is moved to wards/communes, we must first amend the Land Law and revise Decree 102/2024. Additionally, a pilot roadmap is needed. When LRO branch offices were established at the district level in 2013, we also spent two years of piloting before nationwide implementation.

Do you think wards/communes have sufficient capacity to handle land registration and data management?

I can say that it is very difficult, even impossible at this time. More than 80 percent of wards/communes do not meet IT infrastructure standards and lack land-management specialists; the national land database has only completed phase 1 and is not fully synchronized; the Ministry of Agriculture and Environment is still implementing the data digitization project until 2027.

Moreover, if all duties are transferred to wards/communes, infrastructure costs for 3,321 units will be extremely high. The local apparatus will expand, contradicting the Party’s policy of streamlining. Meanwhile, the current 703 provincial LRO branches are operating stably; maintaining them for the next 3–5 years is safer and more suitable.

With the two-tier urban government model, how should LROs be organized?

My view is that the provincial LROs must remain the sole focal point for all technical land functions: registration, title issuance, surveying, and data. Wards/communes should only perform administrative land-management duties: site clearance, land allocation/lease, land-use conversion.

If shifted to wards/communes, we would need a roadmap, staffing, infrastructure, coordination mechanisms and thousands of billions of dong each year in resources, which is not reasonable given the need to streamline the administrative apparatus.

Do you think we need a joint proposal from the Ministry of Home Affairs and the Ministry of Agriculture & Environment to unify the LRO model?

I believe it is essential. Any change involving LRO must be based on scientific assessment: infrastructure, personnel, expertise, and data.

In 2012, ministries drafted Project 447/QĐ-TTg to pilot the consolidation of land registration offices under the former Department of Natural Resources and Environment, which later formed the basis for Decree 43/2015 on LRO functions.

This time, we should follow the same approach to ensure legal consistency and alignment with the two-tier government structure. We must strictly comply with Resolution 57-NQ/TW (2024) on digital transformation breakthroughs and Resolution 66-NQ/TW (2025) on legal reform.

The restructuring of LROs must ensure legality, caution, and avoidance of long-term risks, especially regarding data security and administrative responsibility under the two-tier local government model.

Duy Anh