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The nine stages

Planning and route conception

Bringing the line into the provincial plan and the urban master plan; fixing the alignment, station and depot locations; preparing the route option; provisionally delineating the TOD area.

Who decidesProvincial People’s Committee submits; Provincial People’s Council approves what falls within its authority
Governing instrumentsLuật Quy hoạch đô thị và nông thôn 47/2024/QH15 · Luật Quy hoạch 112/2025/QH15 · Hanoi: NQ 64/2026/NQ-HĐND on underground space planning
What comes outApproved route plan · route option · provisional TOD area boundary
Where it usually goes wrongThe alignment is drawn on a map but not staked on the ground, so site clearance later comes out misaligned. Underground space planning does not yet exist, so the vertical boundary of underground stations cannot be fixed.

Investment policy decision

Preparing the investment policy proposal or pre-feasibility study; appraising the funding source and the ability to balance capital; deciding the investment policy.

Who decidesNational Assembly for projects of national importance · Prime Minister · Provincial People’s Council
Governing instrumentsLuật Đầu tư công 58/2024/QH15 · NĐ 85/2025 (amended by NĐ 275/2025) · NĐ 19/2026 on appraising projects of national importance
What comes outResolution or decision on investment policy · preliminary total investment · funding structure
Where it usually goes wrongPreliminary total investment is built on thin survey data, so the gap is wide when the project is actually prepared. Where the special mechanism waives this step, the settlement file is missing a link people expect to find — prepare the substitute evidence in advance.

Project preparation, appraisal and approval

Construction survey; feasibility study and basic design, or overall technical design under the special mechanism; appraisal by the competent technical authority; fire safety approval and environmental assessment.

Who decidesThe investment decider under delegation; for projects under NQ 188 authority is strongly devolved to the province
Governing instrumentsLuật Xây dựng 135/2025/QH15 · NĐ 209/2026 and NĐ 210/2026 · NĐ 206/2026 on cost management · VBHN 34/VBHN-BXD on overall technical design
What comes outProject approval decision · approved total investment — this is the legal ceiling for every cost that will later be settled
Where it usually goes wrongUnderground quantities are where design and actual ground conditions diverge most. Projects prepared before 30 July 2026 had no dedicated metro standard and had to borrow foreign ones.

Site clearance and resettlement

Land recovery notice; inventory; preparing, posting and approving the compensation, support and resettlement plan; payment; handing over the site in tranches. Runs in parallel with stage 3.

Who decidesThe People’s Committee with authority to recover land and approve the plan
Governing instrumentsLuật Đất đai 31/2024/QH15 · NĐ 88/2024 · NĐ 102/2024 · NĐ 103/2024 · Hanoi, in TOD areas: NQ 66/2026/NQ-HĐND
What comes outLand recovery decision for each parcel · approved compensation plan · site handover records
Where it usually goes wrongThe site is handed over in patches, so the contractor cannot organise a production line and claims standing-time costs. Payment records are missing signatures, and it only surfaces at settlement — by which time the recipients have moved away.

Contractor selection and contract signing

Preparing and approving the contractor selection plan; issuing bidding documents; evaluation; appraisal and approval of the result; negotiation and contract signing.

Who decidesThe competent person and the investor under the Law on Bidding
Governing instrumentsLuật Đấu thầu 22/2023/QH15 (amended by Luật 57/2024 and Luật 90/2025) · NĐ 214/2025 · for PPP: TT 98/2025/TT-BTC and TT 142/2025/TT-BTC
What comes outDecision approving the selection result · contract, with its stated form of contract price
Where it usually goes wrongThe form of contract price written into the contract does not match how the parties actually pay — a lump-sum contract settled on measured quantities, or the reverse. This is the origin of most disputes at settlement.

Construction, cost management and adjustment

Subsequent design steps; preparing, appraising and approving estimates; construction; acceptance of quantities by stage; payment; handling variations and adjustments.

Who decidesThe investor for estimates within the approved scope; the investment decider for project adjustments
Governing instrumentsNĐ 206/2026 on cost management · NĐ 207/2026 on quality management · TT 36/2026, TT 37/2026, TT 38/2026 on norms and costs
What comes outApproved estimates by work item · quantity acceptance records · as-built drawings · payment files by tranche
Where it usually goes wrongNorms are the easiest thing to get wrong — the same work item carries different norms in different periods, and you must use the one in force when the estimate was prepared. Specialised work such as tunnelling and signalling has no domestic norm at all.

Acceptance, trial running and system safety certification

Acceptance of completed items; static and dynamic testing; integrated trial running of the whole system; system safety assessment and certification; State acceptance; operating licence.

Who decidesThe investor carries out acceptance; the technical authority inspects the acceptance work; the sector regulator issues the operating licence
Governing instrumentsLuật Đường sắt 95/2025/QH15 (consolidated text 75/VBHN-VPQH) · NĐ 16/2026 · TT 62/2026/TT-BXD metro technical regulation · VBHN 13/VBHN-BXD on connection to the national railway
What comes outCompletion acceptance records · trial running file · system safety certificate · decision to bring into operation
Where it usually goes wrongThis is the stage that overruns most often. Electricity, operating staff and insurance costs arise while the works are not yet handed over and earn no revenue — whether these are investment cost or operating cost is a question that must be settled in writing beforehand.

Handover, asset recognition and entry into operation

Handing the works and records to the operator; establishing ownership and assigning management of infrastructure assets; preparing asset records, declaration and depreciation; building the fare and subsidy plan.

Who decidesThe authority assigning management of infrastructure assets; the provincial People’s Committee and Council for fares and subsidy
Governing instrumentsNĐ 15/2025 on railway infrastructure assets · TT 75/2025/TT-BTC on depreciation · TT 34/2025 and TT 33/2025/TT-BXD · Luật Quản lý, sử dụng tài sản công 15/2017/QH14
What comes outHandover records by receiving entity · list and value of assets formed through investment
Where it usually goes wrongHandover first, valuation later — trains are running while asset values are not final, the operator books provisional figures, and everything has to be restated once settlement closes.

Settlement of investment capital

Closing and reconciling capital paid; preparing the settlement report; independent audit of the settlement report; verification; approval of settlement; resolving debts and surplus materials and equipment.

Who decidesThe authority approving settlement under delegation; the finance authority leads verification
Governing instrumentsNĐ 254/2025 (replacing NĐ 99/2021) · TT 147/2025/TT-BTC · TT 73/2026/TT-BTC on the system of forms · audit under VSA 1000
What comes outSettlement report · independent audit report · verification report · settlement approval decision
Where it usually goes wrongThe file has passed through several generations of decrees; the people who prepared it have left; early-stage vouchers are lost. Costs not chargeable to asset value are suspended unless the competent authority has permitted them in writing.

Four legal tracks — read the right one

A metro project does not sit under one single set of rules. Which track applies decides which procedures may be shortened and which may not. Getting this wrong at the start is expensive to unwind.

TrackProject type ScopeInstruments
Track AHanoi / HCMC metro, public investmentLocated in Hanoi or Ho Chi Minh CityNQ 188/2025/QH15 · Luật Đường sắt 95/2025/QH15 · VBHN 34/VBHN-BXD
Track BMetro elsewhere, public investmentOutside Hanoi and Ho Chi Minh CityLuật Đường sắt 95/2025/QH15 · Luật Đầu tư công 58/2024/QH15 · Luật Xây dựng. NQ 188 may not be invoked
Track CMetro under a PPPCarried out under a PPP contractLuật PPP 64/2020/QH14 (consolidated text 81/VBHN-VPQH) · NĐ 243/2025 · NĐ 312/2025
Track DTOD area attached to the lineThe zone around stations and depotsLuật Thủ đô 02/2026/QH16 · resolutions of the provincial People’s Council (Hanoi: NQ 71/2025, 66/2026, 67/2026 — HCMC: NQ 21/2026)

Three places where the mechanism is still open

These are not oversights on our part. They are provisions that delegate a further document which has not yet been issued. Until it is, the matter cannot be quantified — and a project that assumes otherwise is building on air.

Hanoi’s TOD advantage coefficient — not yet issued

NQ 67/2026/NQ-HĐND Article 8 assigns the People’s Committee to submit the TOD advantage coefficient and the percentage rates to the People’s Council, once the TOD area plan is approved. That resolution has not been issued. Without it, the four TOD revenue streams cannot be converted into money.

Hanoi’s underground connection fee — not yet issued

NQ 65/2026/NQ-HĐND Article 3.2 assigns submission of the underground connection fee once the underground space plan is approved. Until that document exists, the connection obligation of neighbouring buildings tying into an underground station cannot be determined.

Decree detailing Luật Thủ đô 02/2026 — not found

QĐ 762/QĐ-TTg is the implementation plan for Luật Thủ đô 39/2024, issued before the new law existed. We have found no replacement decision for Luật 02/2026, and no detailing decree.

Where the audit fits

Stages 6 to 9 are where an auditor should already be present, not waiting at the end. See Settlement audit for why, and how the work divides.