The warning was issued by the Ho Chi Minh City Real Estate Association (HoREA) following the implementation of Decision 32/2025/QD-UBND on January 9, 2026.
The regulation sets population thresholds for apartment buildings based on floor area per person, aiming to manage urban density. Under the rules, smaller units are assigned fewer occupants, while larger apartments can accommodate more residents.
However, HoREA's chairman Le Hoang Chau said the policy has led developers to prioritise bigger units, particularly three- to four-bedroom apartments of around 85 sq.m or more, while reducing the supply of mid-sized and smaller homes.
Two-bedroom apartments of 45-70 sq.m and units under 45 sq.m have become less common in new commercial projects, despite strong demand from middle- and lower-income buyers, he said.
The impact is also being felt in social housing, where larger units are increasingly built near the maximum size limits, further limiting affordable options.
According to HoREA, around 60 per cent to 70 per cent of buyers fall into the middle-income segment, typically seeking two-bedroom homes, while 20 per cent to 25 per cent of lower-income households look for one-bedroom units. High-end demand accounts for only a small share of the market.
The association argued that the current population calculation method encourages developers to maximise floor area efficiency rather than align projects with actual demand, creating potential sales difficulties and reducing access to housing for many families.
It added that the assumption of an average 3.5 people per apartment is increasingly outdated, given the trend towards smaller urban households.
To address the issue, HoREA has proposed revising Article 4 of the decision to introduce greater flexibility. It suggested determining overall population limits based on urban planning and national housing strategy benchmarks, such as an average of 32 sq.m per person.
Developers should then be allowed to design apartment structures in line with market demand, while ensuring that units under 45 sq.m account for no more than 25 per cent of total supply and that population caps are not exceeded.
The association said a more flexible approach would support urban redevelopment efforts, including the renovation of ageing apartment blocks and relocation of canal-side housing, while attracting investment and improving access to affordable homes.
