Análisis de las leyes de vivienda social en Vietnam y otros países y recomendaciones para Vietnam Tran Vang-Phu 1 , Duong Anh Son 2 1 Aﬃliation: Ph.D., Ho Chi Minh City University of Economics and Finance. E-mail: phutv@uef.edu.vn; ORCID: 0000-0002-2114-8157 2 Aﬃliation: Assoc. Prof., Ho Chi Minh City University of Economics and Finance. Corresponding Author. E-mail: sonduong@uef.edu.vn; ORCID: 0000-0001-6093-6087 Resumen. El desarrollo de la vivienda social constituye tanto un remedio econó- mico como una importante obligación política y social del país. Mediante una cola- boración meticulosa entre los organismos gubernamentales y los inversores, Vietnam puede asimilar las experiencias de otras naciones y adaptarlas para alinearlas con su contexto interno. Esto se considera una estrategia a largo plazo que fomenta la equidad social. Facilitar la vivienda social para personas de bajos ingresos mejorará la producti- vidad laboral, creando condiciones para un crecimiento económico sostenible. Este ar- tículo compara y analiza principalmente la legislación sobre regímenes preferenciales, sujetos y condiciones para acceder a incentivos de vivienda social en Vietnam y en varios otros países del mundo. Posteriormente, propone métodos para que Vietnam mejore sus políticas de vivienda social. Palabras clave: vivienda social, bajos ingresos, Vietnam, Estados Unidos de América, Corea del Sur, China, Francia. Recibido: 24/07/2025 ~ Aceptado: 15/10/2025 INTERACCIÓN Y PERSPECTIVA Revista de Trabajo Social ISSN 2244-808X ~ Dep. Legal pp 201002Z43506 DOI: https://doi.org/10.5281/zenodo.17641800 Vol. 16 (1): 164 - 179 pp, 2026

Análisis de las leyes de vivienda social en Vietnam y otros países y recomendaciones para Vietnam 165 Vol. 16(1) enero - abril 2026/ 164 - 179 Analysis of social housing laws in Vietnam and other countries and recommendations for Vietnam Abstract. e development of social housing constitutes both an economic rem- edy and a signiﬁcant political and social obligation of the nation. rough meticulous collaboration between governmental bodies and investors, Vietnam can assimilate the experiences of other nations and adapt them to align with its domestic context. is is regarded as a long-term strategy that fosters social equity. Facilitating social housing for low-income individuals will enhance labor productivity, fostering conditions for sus- tainable economic growth. is article primarily compares and analyzes the legislation regarding preferential regimes, subjects, and conditions for accessing social housing incentives in Vietnam and several other countries globally. It subsequently proposes methods for Vietnam to enhance its social housing policies. Keywords: social housing, low-income, Vietnam, Unites States of America, South Korean, China, France. INTRODUCTION Every human being is born with some basic natural rights like the right to life, the right to education, the right to food etc. and the right to shelter (housing) is one of them. e right to housing is a basic human right and it has been recognized as a fundamental right by various inter- national conventions and declarations. Article 25 of the Universal Declaration of Human Rights recognizes the right to housing as part of the right to an adequate standard of living. It states that “Everyone has the right to a standard of living adequate for the health and wellbeing of himself and his family, including food, clothing, housing and medical care and necessary social services, and the right to security in the event of unemployment, sickness, disability, widowhood, old age, and other lack of livelihood in circumstances beyond his control. Similarly, Article 11(1) of the International Covenant on Economic, Social and Cultural Rights (ICESCR) also guarantees the right to housing as part of the right to an adequate standard of living. So, the failure to provide adequate housing results in the violation of human dignity as housing forms an indispensable part of ensuring human dignity (United Nations, Universal Declaration of Human Rights). e right to adequate housing is relevant to all states, as they have all ratiﬁed at least one international treaty referring to adequate housing and committed themselves to protecting this right. By becoming a member of any of the international conventions or covenants these states have an obligation upon them to protect the right of housing of their subjects and to launch various policies and programmes for the upliftment of the weaker sections. Housing is one of the basic human needs. e World Health Organization (WHO) deﬁnes it as a “residential environment which includes, in addition to the physical structure that man uses for shelter, all necessary services, facilities, equipment, devices needed or desired for the physical and mental health and social well-being of the family” (Bernstein et al., 2006). So in simple parlance, a house is a place which should be physically adequate and ﬁt for human habitation and where at least basic human necessities like water, electricity etc., would be easily available. It is equally im- portant that such housing should be aﬀordable by low-income households or that section of society whose income is below the median household income. Having access to quality aﬀordable housing

166 Vang-Phu, Anh Son Interacción y Perspectiva. Revista de Trabajo Social Vol. 16(1): 2026 is fundamental to reducing poverty, improving equal opportunities and guaranteeing sustainable growth. Moreover, it has multiple linkages to other aspects of individual well-being. Housing should not be viewed in the narrow context merely of a few walls and a roof made of bricks. Housing has much wider connotations, impacting human life and dignity. Accordingly, housing needs to be viewed in the larger context consisting of all basic undisturbed rights to shelter, amenities and infrastructures associated with human living, which not only provides an assured quality of life but also empowers and enables people living in the house to be happy, healthy and more productive. ese essentials would include providing; secure tenure, assured water supply, sewerage, sanitation, healthcare and educational facilities, adequacy of living space, taking care of vulnerable sections of the social pyramid, availability of materials for construction etc. Considering the above essentials of housing, here the concept of social housing arises which, to a great extent, fulﬁls the criteria that are needed for achieving the right of housing. As social housing provides long-term homes that enable people to settle. Moreover, social housing is aﬀordable and functions under the target set by the government. e standard says that all homes should be in a good state of repair, safe, secure and warm. Hence to fulﬁll the target of housing and to achieve the goal set by the constitution social housing is much convenient for achieving the same. e government at every stage is and has been making certain policies and providing incen- tives in the form of subsidized loans. to the sections hereinbefore mentioned so that they can af- ford to have access to some basic human necessities. erefore, here the concept of ‘social housing’ arises. Social housing means any rental housing that may be owned or managed by the state, by non-proﬁt organizations, or by both of them, usually to provide aﬀordable housing. Hence it can be said that it is one of the measures whereby the government try to severe the problem of housing inequality (Caves, 2004). However, there are some misconceptions in the minds of the common people about the right to housing. ey think that this right puts an obligation upon the state to build houses for the entire population but in contrast, the state has to focus on the most vulnerable and marginalized groups like low-income households etc. Another misconception about the right to housing is that it prohibits those development projects of the government which could displace people, instead of that the state while enacting those projects has to impose certain conditions and procedural limits on them. RESEARCH METHODS e subsequent research methodologies are implemented in this article: (i) Legal analysis method: an analysis that aims to clarify the wording, content, and scope of application of legal provisions; (ii) comparative legal method: an analysis that identiﬁes similarities and diﬀerences in the legal provisions of the countries selected for research; and (iii) historical research method: an analysis that examines the historical context of the birth and development of a speciﬁc legal provi- sion or institution in order to elucidate the necessity, objects, and scope of regulation of that provi- sion/institution in each period within a speciﬁc historical-economic-social context. Furthermore, secondary data is employed in the study to establish a foundation for the analysis and evaluation of the subject matter and to formulate objective and suitable recommendations.

Análisis de las leyes de vivienda social en Vietnam y otros países y recomendaciones para Vietnam 167 Vol. 16(1) enero - abril 2026/ 164 - 179 RESULTS AND DISCUSSIONS Legal regulations regarding social housing in Vietnam e term “housing” is deﬁned in Clause 1, Article 2 of the 2023 Vietnamese Housing Law, ef- fective August 1, 2024, as a construction work intended for residence and fulﬁlling the living needs of families and individuals. Housing designated for both residential and permissible non-residential purposes is classiﬁed as mixed-use housing. e term “social housing” is deﬁned in Clause 7, Article 2 of the 2023 Vietnamese Housing Law as housing that receives state assistance for individuals eligible for housing support policies in accordance with the provisions of the Housing Law 2023. e author identiﬁes three characteristics of social housing derived from the concepts of “housing” and “social housing” (Vang-phu and Nhu, 2024): Primarily, social housing must constitute actual housing. Consequently, social housing con- stitutes a construction project, a product fabricated according to speciﬁcations, produced through human labor, construction materials, and installed equipment, associated with the land, which may encompass subterranean components, terrestrial elements, aquatic sections, and aerial struc- tures (Clause 10, Article 3 of the 2014 Construction Law, amended and supplemented by Point c, Clause 1, Article 1 of the 2020 amended Construction Law). e state endorses social housing initiatives. State policy signiﬁcantly inﬂuences the expansion of social housing. It inﬂuences all aspects, from the distribution of land and loan capital to stream- lining processes for the advantage of investors, buyers, renters, and hire-purchasers. e restriction on the categories eligible for social housing support policies. Only 12 categories of individuals spec- iﬁed in Article 76 of the 2023 Vietnamese Housing Law are permitted to purchase, lease, or lease- purchase social housing, with each category receiving distinct support policies in various forms. Recipients of preferential policies regarding social housing According to Article 76 of the 2023 Vietnamese Housing Law, there are 12 groups of subjects eligible for social housing support policies, including: (1) People with meritorious services to the revolution, relatives of martyrs who are eligible for housing improvement support according to the provisions of the Ordinance on Preferential Treatment for People with Meritorious Services to the Revolution; (2) Poor and near-poor households in rural areas; (3) Poor and near-poor house- holds in rural areas in areas frequently aﬀected by natural disasters and climate change; (4) Poor and near-poor households in urban areas; (5) Low-income people in urban areas; (6) Workers and laborers working at enterprises, cooperatives, and cooperative unions inside and outside industrial zones; (7) Oﬃcers, professional soldiers, non-commissioned oﬃcers of the people’s armed forces, police workers, civil servants, defense workers and public employees currently serving in the army; people working in secretarial work, people working in other secretarial organizations receiving salaries from the state budget currently working; (8) Cadres, civil servants, and public employees as prescribed by law on cadres, civil servants, and public employees; (9) Subjects who have returned oﬃcial housing as prescribed in Clause 4, Article 125 of the 2023 Housing Law, except for cases of oﬃcial housing revocation due to violations of the provisions of the 2023 Housing Law; (10) Households and individuals whose land is revocation and whose houses must be cleared or demol- ished as prescribed by law but have not yet received compensation from the State in the form of housing or residential land; (11) Students of universities, academies, colleges, vocational schools,

168 Vang-Phu, Anh Son Interacción y Perspectiva. Revista de Trabajo Social Vol. 16(1): 2026 and specialized schools as prescribed by law; students of public boarding schools for ethnic minori- ties; (12) Enterprises, cooperatives, and cooperative unions in industrial parks. Criteria for beneﬁting from social housing support policies Per the stipulations of Clause 1, Article 78 of the 2023 Vietnamese Housing Law, the acquisi- tion or lease-purchase of social housing necessitates the fulﬁllment of two conditions pertaining to housing and income. Initially, residential circumstances Eligible subjects (1), (4), (5), (6), (7), (8), (9), and (10) for the purchase or hire-purchase of social housing must not possess a residence in the province or centrally administered city where the social housing construction investment project is situated, must not have previously acquired or engaged in a hire-purchase of social housing, must not have beneﬁted from any housing support policies in the respective province or centrally administered city, or must own a residence in the same area where the social housing project is located, provided that the average housing area per capita is less than 15 m² of ﬂoor space per person. Additionally, subjects speciﬁed in points b, c, d, đ, e, and g of Clause 1, Article 45 of the 2023 Vietnamese Housing Law must not reside in oﬃcial housing. e particulars are as follows: e absence of personal housing is established when individuals (1), (4), (5), (6), (7), (8), (9), (10), and their spouse (if applicable) are excluded from the Certiﬁcate of Land Use Rights, as well as from ownership of assets linked to land in the province or centrally governed city where the social housing initiative is situated at the time of application for the purchase or lease-purchase of social housing (Clause 1, Article 29 of Decree No. 100/2024/ND-CP dated July 26, 2024, issued by the Government, which elaborates on various provisions of the Housing Law regarding the de- velopment and management of social housing (Decree 100/2024)). If subjects (1), (4), (5), (6), (7), (8), (9), and (10) possess a residence, yet the average housing area per capita is below 15 m² of ﬂoor area per person. Clause 2, Article 29, Decree 100/2024 stipulates that the average housing area per individual is determined by the applicant, their spouse, and any registered permanent residents, including parents and children. Secondly, income criteria Initially, for subjects (5), (6), and (8) referenced above, the subsequent income criteria must be satisﬁed: If the applicant is unmarried, the actual monthly income received must not surpass 15 million VND, as per the Wage and Salary Table validated by the agency, unit, or enterprise of the applicant’s employment. If the applicant is legally married, the combined actual monthly income of the applicant and their spouse must not exceed 30 million VND, as per the Wage and Salary Table veriﬁed by the relevant agency, unit, or enterprise of the applicant’s employment (Point a, Clause 1, Article 30 of Decree 100/2024). e aforementioned individual’s actual monthly income must not exceed 15 million VND if they are single and lack a work contract. Per the law (Clause 2, Article 30, Decree No. 100/2024), the applicant and their spouse must not jointly earn more than 30 million VND per month if mar- ried. ird, the government’s poverty criteria (Clause 3, Article 30, Decree No. 100/2024) stipulate that subjects (2), (3), and (4) must originate from impoverished or near-impoverished households.

Análisis de las leyes de vivienda social en Vietnam y otros países y recomendaciones para Vietnam 169 Vol. 16(1) enero - abril 2026/ 164 - 179 Fourthly, regarding the aforementioned subject (7), the regulations stipulate that if the appli- cant is single, their actual monthly income must not surpass the total income of an oﬃcer holding the rank of Colonel, which includes both basic salary and allowances as per regulations, as veriﬁed by the relevant agency or unit (Clause 1, Article 67 of Decree No. 100/2024); If the applicant is legally married: e applicant and their spouse are both subject to (7) and possess a combined monthly in- come that does not surpass 2.0 times the total income of an oﬃcer holding the rank of Colonel (inclusive of basic salary and allowances as per regulations) veriﬁed by the agency or unit of their employment and management (Point a, Clause 2, Article 67, Decree No. 100/2024); e applicant’s spouse, who is exempt from (7), must possess a cumulative monthly income that does not surpass 1.5 times the total remuneration of an oﬃcer holding the rank of Colonel (inclusive of base salary and allowances as per regulations) veriﬁed by the respective agency, unit, or enterprise of employment (Point b, Clause 2, Article 67, Decree No. 100/2024). If the applicant’s spouse lacks a labor contract, the commune-level People’s Committee shall verify the income requirement. According to Clause 2, Article 78 of the 2023 Vietnamese Housing Law, individuals in categories (1), (4), (5), (6), (7), (8), (9), (10), and (11) are exempt from housing and income criteria when renting social housing. Public housing in South Korea e term “social housing” was ﬁrst utilized in Korea in 2010 (Choi-k, 2020). e term “social housing” is relatively novel and unfamiliar to the Korean populace, whereas “public housing” is more prevalent and recognized by the majority. e 1980s in Korea marked the establishment of the inaugural public housing, which remains functional as social housing to this day. (Ha-s, 2008). Public housing and social housing are distinct terms utilized at various times in Korea. Both terms denote the same concept: assisting individuals in need, particularly those with low incomes, in securing housing amidst scarcity (Choi-e et al., 2016). e Korean government categorizes individuals into ten income groups, with the lowest rep- resenting low-income individuals and the highest denoting the aﬄuent, where ﬁve of these groups are deemed potential beneﬁciaries of government rental housing. Assistance is categorized into three primary groups: individuals responsible for ensuring housing availability, those facilitating home purchases, and those tasked with maintaining stable housing prices. Among the groups with vary- ing objectives, distinct characteristics and support mechanisms exist. Group characteristics: Groups unable to pay rent (Group 1, Group 2); groups unable to purchase their own homes (Group 3, Group 4); groups capable of buying their own homes with government assistance (Group 5, Group 6); groups able to purchase their own homes without assistance (Group 7, Group 8, Group 9, Group 10). e government will construct rental housing areas and oﬀer ﬁnancial assistance for the impoverished who are unable to aﬀord rent; the rental rates will be approximately 30% lower than the market price. e government will assist the low-income demographic by reducing the rental fee by one tier. Groups 3 and 4 will receive support with a rental price 15-16% below the market rate. e Korean government will provide support for the middle-income group, rather than the low-income group, by implementing a lower interest rate to facilitate home purchases. e Korean Government will extend diverse forms of assistance to these groups (Hoang, 2023).

170 Vang-Phu, Anh Son Interacción y Perspectiva. Revista de Trabajo Social Vol. 16(1): 2026 e ﬁrst category involves residential properties available for purchase. Private developers sell medium- to large-sized homes, with regulations adjusted periodically by the state; multi-unit and detached houses (1 million units) are available for groups 4, 5, and 6; small and medium-sized homes (400,000 units) are also sold by private developers on residential land, funded for groups 5 and 6; additionally, state-subsidized housing (700,000 units) is oﬀered to the public for groups 3, 4, and 5. In Korea, the cost of social housing for sale is approximately 80% of the market price. Second category, rental housing: Public rental (300,000 units) (share type, jeonse type) for groups 3, 4, 5; private rental (100,000 units) for group 6; Kukmin rental housing (400,000 units) for groups 2, 3, 4; Yeonggu rental housing (100,000 units) for group 1. Social rental housing is priced at 50% to 80% of the market rate, contingent upon the housing type. In Korea, businesses prioritize the construction of social housing over proﬁt margins, viewing it as a responsibility once the economy experiences robust growth; consequently, the incentives they receive are minimal. Consequently, it is challenging to provide an accurate estimate of the proﬁts generated by businesses investing in social housing. e Korean government will provide capital and ﬁnancial incentives to companies investing in social housing. In particular, socio-economic agents supply housing for individuals in need within the realm of social housing. Socio-econom- ic agents may obtain ﬁnancial assistance, including low interest rates, from the public sector via public-private partnerships, wherein the public sector oﬀers ﬁnancial incentives to suppliers for the provision of social housing (Sang-Hyun et al., 2020). e Korean government must intervene in the market regarding this type of social housing; otherwise, the impoverished will be unable to obtain access to it. Consequently, the government and businesses will jointly contribute to the ad- vancement of social housing in Korea. Public housing in China Since 2001, China’s experience in social housing development has led to the establishment of low-cost rental housing regulations, which were expanded nationwide in 2004, resulting in a transparent housing policy that allocates subsidies to low-income families under state oversight. Subsequently, China transformed social housing development by commercializing construction, distribution, and utilization. e government oﬀers loans to participating enterprises and grants them exemptions from speciﬁc taxes. Low-income housing comprises two categories: for sale and for rent (Le, 2023). Individuals qualiﬁed to purchase or lease a residence must satisfy three criteria: possess a low income relative to the local average, maintain an average housing area of less than 7 square meters per capita, and hold a bank account balance of 90,000 yuan or less (approximately 300 million VND). is condition will be modiﬁed annually to align with the local economic development circumstances. e State Council of China approved the “Guiding Opinions on Social Housing Construction Planning” (Document No. 14) on August 25, 2023. e primary objectives were to “Enhance the construction and provision of social housing” and “Facilitate the development of a new model for the transformation of the real estate industry.” Document No. 14 explicitly identiﬁes the beneﬁciaries of social housing as the low-income “working class,” along with other demographics such as urban households, employees of governmental agencies and organizations, and skilled individuals recruited by enterprises. e increasing urban population, in conjunction with low- and middle-income individuals, will pose a signiﬁcant challenge for social housing in the future (Doan, 2024).

Análisis de las leyes de vivienda social en Vietnam y otros países y recomendaciones para Vietnam 171 Vol. 16(1) enero - abril 2026/ 164 - 179 Public housing in Singapore e Singapore government possesses a remarkable viewpoint on social housing development policy. Providing housing at accessible prices to all citizens, irrespective of their ﬁnancial status, encourages individual motivation to work and fosters savings initiatives. Consequently, individuals who exert greater eﬀort will accumulate suﬃcient funds to acquire their residence more promptly. Singapore’s housing support policy addresses both supply and demand aspects, speciﬁcally through supply-side subsidies that assist businesses via government tax exemptions and reduc- tions, credit support (including long-term loans with low interest rates and grace periods), certain guarantee mechanisms, as well as land and infrastructure provisions. Government subsidies will be provided for privately designed, constructed, and priced apartments, resulting in costs below market value. Singapore possesses eﬃcient, transparent, and expedited administrative procedures that assist private entities engaged in the construction of social housing. Demand-side subsidies are executed by assisting households through various mechanisms, including tax incentives (permitting deductions for low-income housing expenses), subsidies for purchasing or renting residences, sav- ings assistance for home acquisition, and oﬀering preferential loans for property purchases. In 1960, Singapore implemented a state-owned enterprise model for the development of social housing. e Housing Development Board (HDB) of the Singaporean government is solely respon- sible for researching, planning, acquiring land, constructing, developing, distributing, maintaining, and managing social housing. is is a cohesive, specialized, professional entity with explicit and well-deﬁned powers and responsibilities. Consequently, social housing in Singapore is referred to as HDB housing (Le, 2022). e HDB housing initiative primarily targets low- and middle-income families in Singapore. Individuals who fulﬁll speciﬁc criteria, including a designated income level, Singaporean citizenship, and marital status (Nguyen, 2024), may apply to purchase HDB homes via the housing application process. e criteria are delineated as follows (SG property launches, 2025): e primary eligibility criterion for acquiring a HDB ﬂat pertains to citizenship. Singaporean citizens and permanent residents (PRs) are permitted to acquire a HDB ﬂat, although the regula- tions vary slightly for each category. Age constitutes a signiﬁcant criterion in assessing eligibility for a HDB ﬂat. Applicants must be a minimum of 21 years of age to acquire a HDB ﬂat under the majority of schemes. Under the Single Singaporean Citizenship Scheme, individuals may acquire a ﬂat starting at the age of 35. is age criterion embodies the government’s objective of facilitating family establishment and ensuring housing stability for young citizens. Secondly, the Family Core requirement: e notion of family core is fundamental to HDB eli- gibility criteria. To qualify for the purchase of a HDB ﬂat, an applicant must form a family nucleus, which generally comprises a spouse and their oﬀspring, parents and siblings, or dependents under their guardianship. irdly, income ceilings are crucial in assessing eligibility for HDB ﬂats, particularly new units directly from HDB. ese ceilings guarantee that public housing remains accessible to low- and middle-income families. As of 2023, the income threshold for a standard BTO ﬂat is $14,000 for families. Households with incomes exceeding this threshold are ineligible to acquire new BTO ﬂats, thereby guaranteeing that individuals with greater need can obtain aﬀordable housing. Furthermore, applicants must restrict their property ownership to prioritize HDB ﬂats for individuals in genuine need.

172 Vang-Phu, Anh Son Interacción y Perspectiva. Revista de Trabajo Social Vol. 16(1): 2026 Public housing in France In France, social housing, referred to as Habitation à Loyer Modéré (HLM), oﬀers economical rental alternatives for individuals and families with constrained ﬁnancial means. It is intended to guarantee access to stable housing and is administered by governmental bodies and local authori- ties. To be eligible for social housing, applicants must satisfy particular criteria, including: Income limit: Households must not surpass a speciﬁed income threshold, which diﬀers by region and family size; Residence status: Applicants must be legal residents or possess a valid residence permit. Housing necessity: Preference is accorded to individuals in vulnerable circumstances, including those residing in overcrowded environments, experiencing domestic violence, or facing ﬁnancial diﬃculties. Social housing in France refers to residences constructed with state ﬁnancial assistance via social organizations or enterprises, aimed at fulﬁlling the objectives of the Law on the Right to Housing (DALO) to maintain equilibrium among societal components regarding housing require- ments. By oﬀering subsidized rental rates for individuals with low income (below the established threshold). Social housing rental prices are determined by allocation standards and conditions, with the rent per m² assessed by the organization according to established criteria. Consequently, based on individual income levels and particular circumstances, French citizens receive incentives for utilizing social housing tailored to their speciﬁc needs. e International Observatory on Social Housing (2017) delineates priority demographics for social housing. e priority groups encom- pass individuals experiencing homelessness, those at risk of eviction, residents of inadequate hous- ing, overcrowded households, and individuals with disabilities. e government allocates budgetary funds in three ways: direct support for social housing construction projects; exemption of land tax for owners of social housing construction projects; and compensation of the exempted tax to local governments. e Provincial Governor is entitled to retain 30% of the project’s apartments, with 5% allocated for government oﬃcials, in exchange for a preferential value-added tax rate of 5.5% (Nguyen, 2024). Public housing in the United States of America Housing policy, particularly social housing for low-income individuals, is pivotal to the ad- vancement of American society. Consequently, the US government has prioritized and facilitated the development of social housing (Khanh, 2020). e U.S. government periodically reviews low- income housing assistance policies to adapt to evolving economic, market, environmental, and social conditions. In the United States, public housing is characterized as aﬀordable and secure rental accommodation for low-income families, the elderly, and individuals with disabilities. In the United States, Local Public Housing Agencies (PHAs) establish eligibility for public housing based on the following criteria (USA.GOV, 2025). e individual must have either US citizenship or a valid immigration status. Public housing in the United States is government-regulated accommodation oﬀered by pro- prietors at rent-controlled rates on a non-proﬁt basis, allocated administratively according to the needs of low-income households and individuals, with priority given on a ﬁrst-come, ﬁrst-served basis. Additionally, the federal government allocates subsidies to private entities, encompassing both for-proﬁt and non-proﬁt organizations, that manage supportive housing for the elderly and disabled (Ball et al., 1988).

Análisis de las leyes de vivienda social en Vietnam y otros países y recomendaciones para Vietnam 173 Vol. 16(1) enero - abril 2026/ 164 - 179 e Low-Income Housing Tax Credit (LIHTC) program is a federal initiative created by the Tax Reform Act of 1986 to promote the development and preservation of aﬀordable housing in the United States (Everett, 2020). e LIHTC oﬀers tax incentives to private developers to promote the construction or renovation of housing. Tax credits are distributed to states according to population and subsequently subsidized by the state to enterprises undertaking new housing developments for low-income tenants. ese housing projects encompass all or a portion of the apartments designated for low-income tenants for a duration of 15 years from the date of comple- tion. e developer’s credit is determined by the proportion of low-income apartments owned by the project. In the United States, developers play a signiﬁcant role in social housing development programs. e LIHTC program (Xa and et al., 2023) provides investors with credits or incentives to construct aﬀordable housing projects. A comparative analysis of the legal frameworks governing social housing in Vietnam and several other countries globally. A survey of documents from organizations and research projects on global social housing reveals two predominant perspectives: one advocating for social housing as a provision for select individuals, and the other supporting universal access for all in need (Pham, 2016). e former, more widely accepted viewpoint regards social housing as a solution for those lacking income or unable to secure their own accommodation. is perspective is endorsed by numerous nations, including France, South Korea, the United States, and China, thus the provision of social hous- ing is regarded as an embodiment of governmental policy aimed at enhancing the quality of life for citizens, particularly the impoverished. Vietnam is another nation that follows this method- ology. Vietnam designates social housing as a prioritized real estate category, limiting ownership to a speciﬁc group. Article 76 of the 2023 Housing Law speciﬁes that only twelve categories of individuals qualify for special social housing policies. Conversely, individuals in need can access social housing, regardless of their ﬁnancial resources or income levels. Central or local govern- ment entities, along with non-proﬁt housing associations, will subsequently supply social hous- ing to the market. Singapore clearly subscribes to the second perspective. e sale of social hous- ing in Singapore at equitable prices for all citizens, irrespective of socioeconomic status, fosters motivation to work, encourages savings plans, and, most importantly, instills a sense of personal responsibility for one’s future. Upon its initial emergence, social housing primarily served as rental accommodation. Cur- rently, in most countries, social housing is oﬀered to the market in two primary forms: sale and rental. Besides the two fundamental forms of sale and rental, Vietnam also oﬀers the option of social housing lease-purchase. e following is a comparative table detailing social housing transactions, subjects, and eligi- bility criteria for social housing policies, along with incentives for Vietnamese investors and those from Korea, China, Singapore, France, and the United States participating in social housing con- struction (Table 1).

174 Vang-Phu, Anh Son Interacción y Perspectiva. Revista de Trabajo Social Vol. 16(1): 2026 TABLE 1. Key provisons of social housing in Vietnam, South Korea, China, Singapore, France and the U.S. Characteristics Nations Social housing transactions Policy beneﬁciaries support social housing Conditions for enjoying the policy social housing Investment incentives social housing Vietnam •Buy and sell •Lease •Hire purchase Limiting the beneﬁciaries of social housing policies. ere are only 12 groups of beneﬁciaries listed in Article 76 of the Housing Law 2023. •For sales and hire-pur- chase transactions: meet 2 conditions on housing and income. •For social housing rental transactions, it is only ne- cessary to have the right target, without having to meet housing and income conditions. •Exemption from land use fees and land rent; •Value added tax, corporate income tax; •Enjoy a maximum proﬁt of 10% of the total cons- truction investment cost for the social housing construction area; •Up to 20% of the total residential land area within the project area has been invested in building te- chnical infrastructure systems to invest in building business, commercial and residential services; •Get loans with preferential interest rates; •e Provincial People’s Committee supports the connection of the project’s technical infrastructu- re system with the regional technical infrastructu- re system, ensuring synchronization of social in- frastructure within and outside the project scope. South Korea •Buy and sell •Lease People have low income ere are 10 groups of subjects. Based on income Enjoy capital and ﬁnancial incentives. China •Buy and sell •Lease •Low-middle income workers. •It also includes other groups such as urban households, employees of government agencies and organizations, and talent attracted by bu- sinesses. Must meet 3 conditions: •Income: low income compared to local average income; •Housing: average housing area is less than 7 m2/per- son; •Have a bank account: 90,000 Yuan or less (about 300 million VND). Companies involved in building social housing are given loans from the government and exempted from certain taxes.

Análisis de las leyes de vivienda social en Vietnam y otros países y recomendaciones para Vietnam 175 Vol. 16(1) enero - abril 2026/ 164 - 179 Characteristics Nations Social housing transactions Policy beneﬁciaries support social housing Conditions for enjoying the policy social housing Investment incentives social housing Singapore •Buy and sell •Lease Open to all Singapore citizens •Income: as of 2023, the income ceiling for a ty- pical BTO apartment is $14,000 for families; •Nationality: Singapore citizen and permanent resident; Marriage: the applicant must form a family unit. •In addition, must meet age requirements (21 years or older). Applicants are also required to limit their property ownership, to ensure that HDB ﬂats are given priority to those in genuine need. •Government tax exemption and reduction; •Credit support (long-term loans with low interest rates, grace period loans); •Provide some guarantee mechanisms, provide land, infrastructure. •Apartments designed, built and priced by private individuals will be subsidized by the Government at a price lower than the market price. In addition, private organizations participating in the construction of social housing in Singapore are also supported by the State with clear, transparent and quick administrative procedures. France •Lease Low-income people. ere are priority groups for social housing: Homeless; People at risk of eviction; People living in substandard housing; Overcrowded households; Disabled. •Income limits: house- holds must not exceed an income threshold, which varies by region and fa- mily size; •Residency status: appli- cant must be a legal resi- dent or have a valid resi- dence permit; •Housing needs: priority for individuals in preca- rious circumstances. •Land tax exemption for social housing project ow- ners: e government compensates the exempted tax amount to the local government; •Applying a preferential value-added tax rate (5.5%), in return the Governor has the right to retain 30% of the project’s apartments, of which 5% is reserved for government oﬃcials. e U.S •Lease Low-income families and individuals. Old person. People with disabilities. •Total annual income; •Qualify as a senior, di- sabled person or family member; •US citizenship or immi- gration status. e federal government provides grants to private organizations; LIHTC provides tax incentives to developers to encourage the construction or renovation of homes; e government provides credits. Fuente: Compined by author. TABLE 1. CONTINUACIÓN

176 Vang-Phu, Anh Son Interacción y Perspectiva. Revista de Trabajo Social Vol. 16(1): 2026 It is evident that not only Vietnam, but also numerous countries worldwide, including Sin- gapore, South Korea, France, China, and the United States, implement social housing policies to address the housing needs of low-income individuals at a fundamental level. Each country has dis- tinct regulations, stipulations, and incentives for investors regarding social housing policies and the construction of such housing. ese regulations are contingent upon the socioeconomic conditions of the nation. Notwithstanding these disparities, the predominant objective remains the provision of aﬀordable housing to guarantee social security, thereby enhancing individuals’ quality of life. Providing housing is a signiﬁcant humanitarian strategy and is recognized as a political objective, playing a crucial role in the robust development of the nation’s economy. CONCLUSION AND RECOMMENDATIONS FOR VIETNAM Given the persistent escalation of commercial housing prices to unprecedented levels, advanc- ing the development of the social housing sector is deemed a crucial strategy to address the existing deﬁcit of aﬀordable housing, fulﬁll the populace’s housing requirements, and uphold social stabil- ity. Achieving the established objectives necessitates supplementary solutions that can engage and attract both investors and home purchasers. e author proposes the subsequent recommendations: Social housing is a policy of signiﬁcant humanistic importance as it addresses the individual aspiration of establishing stability and pursuing a career. From 2021 to the present, a synthesis of local reports indicates that 655 social housing projects have been executed nationwide, encompass- ing 593,428 units. Of these, 103 projects have been completed, totaling 66,755 units; 137 projects have commenced construction, amounting to 114,618 units; and 415 projects have received in- vestment approval, comprising 412,055 units. To date, 66,755 apartments have been completed, representing approximately 15.6% of the project’s goal for 2025 (Minh, 2025). A primary reason social housing projects have failed to meet their objectives is the complexity and entanglement of legal procedures. Despite distinct regulations for social housing, administrative procedures remain lengthy, resulting in extended project completion times that adversely impact investment eﬃciency. For instance, the implementation of commercial housing projects involves numerous procedures; however, social housing projects fundamentally adhere to similar procedures. Social housing proj- ects are exempt from land price determination procedures; however, they are required to under- take procedures for establishing selling prices. e social housing policies established by the 2023 Housing Law are signiﬁcantly enhanced in comparison to those outlined in the 2014 Housing Law. Coordination and facilitation among law enforcement agencies are necessary, with an emphasis on ensuring progress and preventing delays. Prolonging time entails ﬁnancial resources, labor, and returns for investors. Consequently, Vietnam ought to emulate Singapore’s approach of endorsing social housing investors by instituting clear, transparent, and expedited administrative procedures to assist investors in the construction process and reduce bureaucratic obstacles. Consequently, it will incentivize businesses to engage in construction, thereby augmenting the availability of social housing. e preferential policies for investors in social housing projects in Vietnam are insuﬃciently appealing. Limitations on proﬁt margins render social housing projects less appealing compared to commercial housing. Numerous enterprises contend that constructing social housing is more challenging than erecting commercial housing due to the implementation mechanism, wherein investors are restricted to a maximum proﬁt of 10% despite their investment in construction.

Análisis de las leyes de vivienda social en Vietnam y otros países y recomendaciones para Vietnam 177 Vol. 16(1) enero - abril 2026/ 164 - 179 Consequently, it is essential to increase the social housing proﬁt margin for investors to 15% from the stipulated 10% in Point c, Clause 2, Article 85 of the 2023 Housing Law. Increasing the proﬁt margin will incentivize investors to engage in the development of social housing, a crucial sector in addressing the housing requirements of low-income individuals. Enhanced policies for investors are essential to expedite the achievement of the objective of constructing a minimum of one mil- lion social housing units. Clarifying the responsibilities of the state and investors is also essential. Investors are more likely to engage in social housing projects when they acknowledge the potential and governmental support, thus yielding tangible beneﬁts for the populace and fostering the na- tion’s sustainable development. When investors perceive the construction of social housing as their obligation and anticipate “substantial” proﬁts, they will be more eﬀective in providing housing for individuals. In a manner akin to how social housing investors in Korea perceive the development of social housing as their obligation. Only then will the Vietnamese economy experience more vigorous growth in the future, as stable housing incentivizes individuals to engage in labor and production. ird, rental social housing models are present not only in Vietnam but also in numerous countries worldwide, including South Korea, China, France, Singapore, and the United States. Nonetheless, not all individuals in Vietnam are aware of their eligibility to rent social housing. Consequently, they frequently lease long-term rental apartments. e rental apartments’ pricing will be determined by the landlord, resulting in costs exceeding those of social housing. Long-term rental apartments are typically occupied by individuals with limited ﬁnancial resources, includ- ing laborers, public servants, students, and low-income individuals. Nonetheless, long-term rental apartments in Vietnam have not been classiﬁed as social housing. Designating long-term rental apartments as social housing will not only provide workers with stable, aﬀordable, and high-quality housing but also alleviate the burden on extensive social housing initiatives. is is a pragmatic solution for the development of sustainable housing, tailored to the requirements of millions of workers and low-income individuals in major urban areas. Furthermore, landlords receive tax and credit incentives for infrastructure upgrades and renovations, along with reduced rent, electricity, water prices, and related service expenses. Fourth, Vietnamese legislation should draw insights from the French social housing model regarding the prioritization of speciﬁc groups eligible for social housing assistance policies. e es- tablishment of regulations regarding the hierarchy of eligibility for purchasing, renting, or rent-to- own social housing in social housing initiatives is a pragmatic approach to guarantee equitable and just distribution of social housing, catering to individuals genuinely in need. e housing require- ments of cadres, civil servants, and public employees diﬀer signiﬁcantly from those of impoverished households in rural areas, while the latter also have distinct housing needs and support mechanisms compared to workers in industrial zones. BIBLIOGRAPHIC REFERENCES • Ball, M., Harloe, M., and Martens, M. (1988). Housing and Social Transformation in Europe and the USA, Routledge Publishing. • Bernstein, M., Kim, J., Sorensen, P., Hanson, M., Overton, A., & Hiromoto, S. (2006). Aﬀordable Housing and Lessons Learned from Other Natural Disasters. In Rebuilding Hou- sing Along the Mississippi Coast: Ideas for Ensuring an Adequate Supply of Aﬀordable Housing

178 Vang-Phu, Anh Son Interacción y Perspectiva. Revista de Trabajo Social Vol. 16(1): 2026 (pp. 7-16). Santa Monica, CA; Arlington, VA; Pittsburgh, PA: RAND Corporation. Retrie- ved May 31, 2020, from www.jstor.org/stable/10.7249/op162rc.10 • Cautioneo (2025). Social Housing in France: Application and Qualiﬁcation Process, https:// www.cautioneo.com/blog/social-housing-france/#:~:text=Social%20housing%20in%20 France%2C%20known,government%20agencies% 20and% 20local%20authorities, [acces- sed March 15, 2025]. • Caves, R., W., (2004). Encyclopedia of the City. Routledge. • Choi, E., Kwon, S., Jin, N., Jeon, J., Han, J. A. (2016). Research on the Activation of Social Housing Supply, e Korea Center for City and Environment Research: Seoul, Korea. • Choi, K. (2020). Housing service case and future outlook for the third section. Within Hou- sing Service Insight. Korea Housing Service Society, Editor; Park Young Sa: Seoul, Korea, 2020; pages 115–149. • Doan, V., B. (2023). Insights into the development of social housing in various countries glo- bally and recommendations for enhancing social housing development policies in Vietnam, https://danchuphapluat.vn/kinh-nghiem-phat-trien-nha-o-xa-hoi-tai-mot-so-quoc-gia-tren- the-gioi-va-goi-mo-giai-phap- hoan-thien-chinh-sach-phat-trien-nha-o-xa-hoi-cho-viet-nam, [accessed March 14, 2025]. • Everett, S. (2020). An Overview of the Low-Income Housing Tax Credit (LIHTC), https:// taxfoundation.org/research/all/federal/low-income-housing-tax-credit-lihtc/ ,[accessed 03/17/2025]. • Ha, S. (2008). Social housing complexes and sustainable community advancement in South Korea. Habitat International 2008, 32, 349–363. • Hoang, Q. (2023). Social housing available for rent to individuals and workers—insights from Korea, https://laodong.vn/cong-doan/nha-o-xa-hoi-cho-nguoi-dan-cong-nhan-thue-- kinh-nghiem-tu-han-quoc-1231759.ldo, [accessed March 16, 2023]. • International Observatory on Social Housing (2017). Overview of French Social Housing, https://internationalsocialhousing.org/2017/05/01/french-social-housing-in-a-nutshell/, [ac- cessed March 16, 2025]. • Khanh, P. (2020). Insights gained from the development of social housing in developed na- tions, http://baoxaydung.com.vn/bai-hoc-kinh-nghiem-phat-trien-nha-o-xa-hoi-cua-cac- nuoc-phat- trien-286219.html, [accessed March 15, 2025]. • Le, D. (2022). Singapore’s successful narrative in social housing development, https://bnews. vn/singapore-va-cau-chuyen-thanh-cong-trong-phat-trien-nha-o-xa-hoi/259690.html, [ac- cessed March 14, 2025]. • Le, Q. (2023). What are the methods employed by South Korea, China, ailand, and Singapore in the development of social housing? https://thanhnien.vn/han-quoc-trung- quoc-thai-lan-singapore-phat-trien-nha-o-xa-hoi-ra-sao-185230403162446896.htmgidzl= qMzb5MMc8nRKS68HPRah4z9mQHLvxI0Hp7Gq5t6_THx093LF8BrsJPrtOXX-jd4T- mtPaJpQ5-70mPgKY5G, • Minh, T. (2025). A novel mechanism enhances the appeal of investment in social housing, https://baodauthau.vn/co-che-moi-tang-suc-hap-dan-dau-tu-nha-o-xa-hoi-post176118.html ?gidzl=DoRQ6HIGtLGoETqT58tULpGptH48XzvQAZcC55k9t5zwRTKON8w21oi-Wqq CZT4AU3_LG3KIXp5-5vFSLm, [accessed March 27. • Nguyen, H., H. (2024). Social housing constructed by HDB—Singapore, Architecture Ma- gazine, Issue 1 (April 2024).

Análisis de las leyes de vivienda social en Vietnam y otros países y recomendaciones para Vietnam 179 Vol. 16(1) enero - abril 2026/ 164 - 179 • Nguyen, T., D. (2024). Social planning—Expertise in the development of social housing in the French Republic, https://www.acvn.vn/noxh-quy-hoach-mang-tinh-xa-hoi-kinh-nghiem- phat-trien-nha-o-xa-hoi-tai-cong-hoa-phap.html, [accessed March 14, 2025]. • Pham, T., T.m, H. (2016). International experience in social housing development and in- sights for Vietnam, Journal of Construction Science and Technology, No. 29 (June 2016), page 43. • Chung, S., Kim, S., Park, S., Kim, H. (2020). e Past, Present, and Future of Social Hou- sing in Seoul: What Is the Direction of Social Housing? https://www.mdpi.com/2071- 1050/12/19/8165, [accessed 18 March 2025]. • Singapore Property Launches (2025). Who Is Qualiﬁed to Purchase HDB in Singapore? Acqui- sition of HDB, https://singaporepropertylaunches.sg/buying-hdb/, [accessed 16/03/2025]. • ach, B. (2024). Social Housing Development—Part 3: Insights from China, https:// baotintuc.vn/bat-dong-san/phat-trien-nha-o-xa-hoi-bai-3-kinh-nghiem-o-trung- quoc-20240405065435298.htm, [accessed March 17, 2025]. • Vang-Phu, T., and Nhu, H. T. H., (2024). Legislation on preferential treatment for inves- tments in social housing construction projects, Ho Chi Minh City National University Press, pages 31, 32. • USA.GOV (2025). Public housing, https://www.usa.gov/public-housing, [accessed March 18, 2025]. • Xa, K., O., Nguyen, V., D., Nguyen, V., L. (2023). Legislation regarding preferential policies and assistance for social housing development in the United States and its implications for Vietnam, Ho Chi Minh City University of Law, page 35.