The three "50 years" in the file — and which one is NOT your title deed
The SkySOLIS file contains two separate 50-year periods, and both of them bind the developer rather than appearing on the certificate issued to a buyer.
First — a 50-year project implementation period, under Decision 2074/QĐ-UBND dated 15 August 2023. This is the operating term of the investment project under clause 2, Article 44 of the 2020 Investment Law.
Second — a 50-year land use term counted from the effective date of the decision, under Decision 3764/QĐ-UBND dated 23 June 2026. This is the term for which the State allocates the land to the developer in order to carry out the project, determined under point c, clause 1, Article 172 of the 2024 Land Law.
Third — the term written on the buyer's pink book (certificate of title). That figure does not exist yet: no certificate has been issued to any customer of this project. It will be determined by the issuing authority at the time of issuance, based on the project's legal file and the signed sale and purchase agreement.
The legally interesting point lies in the land category: under Decision 3764/QĐ-UBND, the land on which the building sits is urban residential land (mixed-use high-rise) of 9,443.5 m² — not commercial and service land. Clause 1 of Article 171 of the 2024 Land Law places residential land in the category of land used stably and long-term, and clause 6 of Article 148 provides that where a mixed-purpose building is created on residential land, the land use term is stable and long-term.
Even so, we do not assert "long-term pink book". The legal basis pointing in that direction exists, but no certificate has in fact been issued to any customer of this project. Our recommendation: have the land use term and the ownership term for the property written expressly into the sale and purchase agreement before you sign.
A separate note on the other two product groups: the 222 serviced-office units and the 20 shophouses are not "housing" under the 2023 Housing Law — the notice of commencement itself separates 384 people in the "non-permanent stay" category from the 2,343 people attributed to the apartments. For these two groups, the ownership term of the property is as set out in the sale and purchase agreement. Read the term clauses carefully before signing.
Finally, do not confuse the land use term with the service life of the building. Article 58 of the 2023 Housing Law determines the service life of an apartment building from its design documents and inspection conclusions, counted from the date it is accepted and put into use — for SkySOLIS that is 100 years by design. And when an apartment building reaches the end of its service life and must be demolished, point b of clause 7, Article 70 of the 2023 Housing Law still protects the owner's land use rights.
Bank guarantee and payment caps — the part most often overlooked
Article 26 of the 2023 Law on Real Estate Business requires the developer to obtain a bank's agreement to guarantee its financial obligations to the buyer in the event that the home is not handed over as committed. A copy of the bank's written commitment must be given to the buyer when the contract is signed.
Clause 6 of Article 26 provides that the guarantee letter is issued to the buyer within 10 working days from the date the contract is signed, and that the developer may only receive payment after the buyer has received that letter. Clause 3 allows the buyer to choose whether or not to have a guarantee — we recommend always choosing to have one, and paying nothing at all before the guarantee letter is in your hands.
On the payment schedule, Article 25 sets the caps: the first payment (including any deposit) must not exceed 30% of the contract value; the total before handover must not exceed 70%; and it must not exceed 95% until the buyer has been issued the certificate of title.
One detail matters here: if the seller is a foreign-invested economic organisation under clause 4, Article 10 of the Law, the ceiling before handover is 50% rather than 70%. Because SkySOLIS is carried out by an entity belonging to a Malaysian group, this is a point to be confirmed specifically rather than assumed. We will check it and obtain written confirmation from the developer before you place any deposit.
Why the project is exempt from a construction permit — and what that actually means
Some pages state that SkySOLIS "has been granted a construction permit". According to the file, that is not the case: on 12 August 2026 the Ho Chi Minh City Department of Construction issued Official Letter No. 29199/SXD-QLXDCT confirming that the works fall within the cases exempt from a construction permit.
Exemption does not mean the procedure is skipped. It is a mechanism under Construction Law No. 135/2025/QH15 (passed by the National Assembly on 10 December 2025): where the specialist construction authority has appraised the feasibility study report and the project has been approved, the same set of documents does not have to go through a permit application again. For SkySOLIS, those two steps are Official Letter 27740/SXD-QLXDCT dated 31 July 2026 and project approval decision No. 19-2026/ATP-QĐ dated 1 August 2026.
The legal basis cited by the Department of Construction is point e, clause 2, Article 43 of Law on Construction No. 135/2025/QH15: "A construction work belonging to a construction investment project for which the specialised construction authority has appraised the feasibility study report or the adjusted feasibility study report, and which has been approved in accordance with regulations." You can compare this directly against the text of the Law.
In return, under point b, clause 3, Article 43, the developer must still submit the same set of documents as a permit application would require, less only the application form itself, together with the notice of commencement. That notice was issued on 13 August 2026 and has been recorded by the authority in the national database on construction activity.
On the level of quality supervision: Official Letter 29199 classifies SkySOLIS as a Group B project, Grade I civil works, with a design service life of 100 years. The fire prevention and fighting design was appraised separately by the Ho Chi Minh City Police in Official Letter 7408/PC07-Đ2 dated 11 May 2026.
Does the permit exemption affect the sale of apartments?
No. The 2023 Law on Real Estate Business anticipates both situations. Clause 3 of Article 24 sets out two parallel groups of documents: point a is the construction permit where one is required, and point b is the notice of commencement together with the construction design documents where a permit is not required.
The two points carry equal legal weight. A project exempt from a permit still qualifies to sell off-plan housing, via point b.
In addition, for apartment buildings and mixed-use buildings containing housing, point c of clause 3, Article 24 also requires evidence that the foundation works have been inspected and accepted — and clause 4 of Article 24 requires the developer to hold a written confirmation from the provincial authority that the housing is eligible for sale. That written reply is published on the national housing and real estate market portal, where anyone can look it up.
This schedule was compiled from the file supplied by the developer to its distributor, current as at 25 August 2026. It is reference information, not legal advice, and it does not replace checking the originals yourself.
