On November 5, the Ho Chi Minh City Institute of Natural Resources and Environment Economics (IEEr) continued to send a document to the Ministry of Home Affairs, the Ministry of Public Security and the Ministry of Agriculture and Environment proposing to consider rearranging the model of the Provincial Land Registration Office (LRO) in accordance with legal regulations and the actual operations of the two-level local government.
According to IEEr, this recommendation is based on Official Dispatch No. 10217/VPCP-TCCV dated October 22, 2025 of the Government Office , in which the Prime Minister assigned the Ministry of Home Affairs to consider the institute's proposal to maintain the provincial-level land registration office model and postpone the transfer time to the commune level.
The Institute believes that with the specific nature of the natural resources sector, maintaining a provincial office is consistent with current policies and laws and ensures effective State management of land.
Dr. Pham Viet Thuan, Director of IEEr, said that Report No. 9864/BC-BNV dated October 29 of the Ministry of Home Affairs mentioned "arranging the staff of the Office of Registration of Land Use Rights to manage at the commune level". However, the Institute found that this content lacked legal basis, because Notice No. 371-TB/VPTW dated October 4 of the Central Office and Official Dispatch No. 20/CV-BCĐ of the Government Steering Committee did not mention transferring the staff of the Office of Registration of Land Use Rights to the commune level.

A bustling business registration office in Ho Chi Minh City
According to IEEr analysis, the natural resources sector is highly technical, especially in the fields of surveying, mapping, determining land plot boundaries and managing digital data. The “cleaning” of land data requires synchronization and continuous inheritance, which can only be ensured if the data is managed uniformly at the provincial level. Therefore, the process of digitizing natural resources data needs to be implemented according to a two-level government model, in which the provincial Land Registration Office plays a central role in terms of technology, data and professional personnel.
On that basis, the IEEr Institute recommends two specific options. The first option is to separate functions: the provincial Land Registration Office is in charge of natural resource engineering, while the commune level is in charge of land administration. The organization must comply with the 2024 Land Law, Decree 102/2024 and Resolution 316/NQ-CP/2025, while maintaining the professional role of the provincial Land Registration Office.
The second option is to maintain the provincial Land Registration Office as the sole focal point to receive and process all procedures related to resources and land, including first-time issuance of certificates, to ensure streamlined commune-level government, reduce administrative burden and improve management efficiency.
Mr. Thuan emphasized that it is necessary to maintain the provincial registration office because this is a special field that requires high technical skills and is directly related to the national digital transformation strategy on resource data. Changing the model without a clear roadmap could cause major disruption.
Source: https://nld.com.vn/kien-nghi-moi-lien-quan-den-van-phong-dang-ky-dat-dai-cap-tinh-1962511050944072.htm






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