Following on from the key updates to the Law on PCCC & Rescue 2024 introduced in Part 1, this article delves into specific regulations, the requirements for coordination between design, construction, and operation teams, as well as the legal responsibilities that project developers and property management units must clearly understand. In the context of an increasingly stringent and transparent legal framework, understanding and correctly applying the new standards is not only a legal requirement but also a crucial factor in ensuring safety, optimising costs, and maintaining sustainable building operations. 

1. Developing and practising fire prevention, fighting & rescue plans: Streamlining procedures to enhance operational accountability 

The change to unify fire prevention, fighting and rescue plans into a single, continuous process applicable to buildings and vehicles aims to standardise and synchronise emergency response efforts while imposing higher requirements for practicality and readiness at each facility. 

Notably, the previous approval procedure for fire prevention, fighting, and rescue plans has been replaced by the head of the facility (inclusive of the developer, management board, and daily operations) is responsible for developing and organising regular drills in accordance with Form PC06 issued alongside Decree 105/2025/NĐ-CP. This form includes elements such as scenario planning, task assignment, and the allocation of personnel and necessary equipment. 

The simplification of procedures saves implementation time but simultaneously requires units to proactively assess actual risks and conduct thorough drills. The plan is no longer a mere formality but serves as the basis for assessing legal responsibility in the event of an incident, especially in cases of violations related to periodic training or inadequacies in the plan’s content. 

Read more: Health and Safety in Property Management 

Essential components to be included in the plan are: 

• Analysis of real hazard scenarios: fires in basements, ability to spread between floors, total power outage. 

• Integration of rescue elements: people trapped in lifts, asphyxiation, ceiling collapse. 

• Ensuring full participation: on-site fire prevention and fighting teams, residents, security personnel, and technical units. 

• Conducting post-drill evaluations to draw lessons learned and maintaining records as a basis for inspections. 

Legal source: Decree 105/2025/NĐ-CP – Articles 15 & 16 

2. Organising Fire Prevention and Fighting & Rescue Teams: Clear Role Classification – Simplified Staffing Structure 

Decree 105/2025/NĐ-CP is revised to include regulations concerning the organisation of fire prevention, fighting & rescue teams, streamlining personnel while enhancing operational effectiveness. It clearly defines the roles of each group while ensuring efficient on-site response capabilities. 

For developers and property management units, accurately identifying the type and scale of the building is crucial for allocating personnel appropriately and preventing unnecessary staffing arrangements, improper multitasking, or failure to meet the minimum legal requirements for team organisation. 

Key Points: 

• Application of multitasking for grassroots and militia forces: Facilities are not required to maintain dedicated teams if the building’s scale and nature do not demand it. However, those with multitasking roles must receive adequate training, have clear assignments, and bear specific responsibilities. 

• Classification of specialised fire prevention,  fighting & rescue teams: Depending on the fire and explosion risk level, and building scale, specialised teams may be formed. This is essential for developers in industrial, logistics, and manufacturing sectors to clearly understand their responsibility in training appropriate teams. 

• Requirement for facilities with 20 or more employees: Establishing a facility-level fire prevention and fighting & rescue team is mandatory. Many offices, shopping centres, and medium-sized apartment buildings fall under this category. 

• Requirement for facilities with under 20 employees: Facilities must designate specific individuals to perform fire prevention and fighting & rescue duties. This role cannot be left vacant. 

• Addition of regulations for volunteer fire prevention and fighting & rescue teams: This provides clearer legal framework for facilities with special management models or those within residential communities. 

Property management units need to review their current organisational models, especially in complexes and apartment buildings with multiple owners, to ensure compliance with the new regulations and avoid the risk of penalties or suspension due to improper team organisation. 

Legal source: Decree 105/2025/NĐ-CP – Articles 20 & 21 

3. Management of fire prevention, fighting & rescue equipment and materials before circulation: Tightening control from the market stage 

A significant change is the requirement to present a list of fire prevention and fighting, as well as rescue equipment, materials, and components, which must all be licensed before being released to the market. For developers and management units, this imposes strict control requirements from the design and procurement stages through to system installation. 

This includes but is not limited to: 

• Fire prevention, fighting & rescue equipment must be licensed by the provincial fire prevention, fighting & rescue Police department before use in buildings. 

• Fire-resistant materials and components must be approved by specialised construction authorities (delegated according to the Ministry of Construction’s regulations). 

• Licenses apply to specific models, meaning that once a product model is approved, similar products can be manufactured, assembled, imported, and circulated on the market without requiring separate approval for each batch. 

• Appendix V attached to Decree 105/2025/ND-CP clearly lists the equipment and materials that must be licensed. This serves as a critical legal basis to be carefully checked during the preparation of fire safety equipment budgets or when approving materials from contractors. 

Ensuring full control over the origin and licensing of fire prevention and fighting & rescue equipment is a crucial factor in the acceptance and commissioning of a building. Developers and property management units must coordinate to regularly inspect, perform maintenance, and replace materials and equipment to ensure compliance with regulations and maintain system effectiveness. 

Legal source: 

• Decree 105/2025/ND-CP – Appendix V 

• Circular 36/2025/TT-BCA – Article 11 

4. Updating the fire prevention, fighting & rescue database 

One significant change regarding the responsibility for information updates is the unified operation of the nationwide fire prevention and fighting & rescue database. Information from developers and management units now serves as the basis for internal inspections and constitutes mandatory data that must be declared and maintained online. 

Key obligations: 

• Adding detailed data on each facility: including information to support the state management activities of the fire prevention, fighting & rescue forces. It is no longer limited to legal documentation. 

• Provision and maintenance of fire alarm transmission equipment: 

  - Household owners (in centrally governed cities) and facility heads must cover the costs of maintaining this equipment themselves.

  - Fire alarm transmission devices must be connected to the fire prevention and fighting & rescue Database no later than 1 July 2027.

  - Building management units must work with developers to establish appropriate investment plans for connection equipment and ensure timely, regular maintenance. Delays in implementation may impact periodic inspection outcomes or the validity of fire insurance documentation. 

Legal source: Decree 105/2025/NĐ-CP – Articles 24, 25, 26, and 27 

Read more: From design to operations: Fire safety in building construction 

5. Fire Prevention, Fighting & Rescue Training: Tightened Procedures – Clearer Authority Boundaries 

Compared to previous regulations, the new provisions remove unnecessary administrative procedures while clearly re-defining the authority and training content for each target group. 

Key points: 

• Training authority: Only the Police and the University of Fire Fighting and Prevention are now authorised to conduct professional training and refresher courses. This change standardises programmes and ensures consistent training quality. 

• Training content and duration are now clearly classified: Tailored to each target group (i.e. building management staff, fire protection system operators, or part-time community fire prevention teams.) 

• Abolition of administrative procedures related to the approval of training content by the facility: While this reduces the administrative burden for investors, it requires property management units to take a proactive approach in liaising with authorised training providers. 

For complex buildings, industrial facilities, and shopping centres, the management unit should proactively review the list of personnel subject to mandatory training and develop a coordination plan with the local police to ensure compliance with the required deadlines. 

Legal source: Decree No. 105/2025/NĐ-CP – Articles 28, 29 and 30 

6. Mandatory Fire and Explosion Insurance: Updated Coverage List and Financial Obligations 

The new decree comprehensively revised the policy on mandatory fire and explosion insurance. This particularly affects developers of commercial buildings, leased office spaces, and industrial zones, which are classified as high fire and explosion risk according to Appendix VII. 

Key highlights: 

• Updated list of facilities required to purchase insurance: Obligations must be cross-checked with Appendix VII to determine applicability. 

• Increased contribution for fire prevention and fighting & rescue activities from 1% to 2%: This insurance premium is allocated to support fire prevention activities. 

• Clear specification of insurance premiums and compulsory deductible levels: Detailed guidance is provided in Appendix VI. 

Developers need to coordinate with insurance providers to ensure not only legal compliance but also that the policy is appropriate for the specific characteristics of the facility. Property management units must ensure that insurance contracts remain valid, a mandatory requirement when interacting with inspection authorities or applying for Fire Prevention and Fighting safety certification. 

Legal source: Decree 105/2025/NĐ-CP – Article 35 

7. Increased Penalties and Expanded Scope of Administrative Violations 

Decree 106/2025/NĐ-CP has expanded the penalty framework in the field to cover upwards of 151 violations. This includes 78 new offences, with many fines significantly increased. This highlights the need for proactive compliance, particularly for developers and property management units. 

Key Changes: 

• Four new groups subject to penalties: 
  - Subsidiaries of cooperatives. 
  
  - Organisations established under the Commercial Law. 
  
  - State agencies and legally recognised condominium management boards. 
  
  - Organisations directly assigned to manage a facility. 

• Seven new articles aligned with the 2024 Fire Prevention and Fighting & Rescue Law, including provisions for incidents where a fire occurs but does not meet the threshold for criminal liability. 

• Increased fines for many violations, particularly those related to the design, construction, and acceptance of fire prevention and fighting systems. 

• Introduction of “temporary suspension of operations” for six categories of serious violations, including: 
  - Failure to ensure adequate escape routes. 
  
  - Violations concerning fire prevention and fighting equipment provision. 
  
  - Construction deviating from approved fire prevention and fighting designs. 

Apartment buildings, office complexes, and production facilities need to pay particular attention, as the occurrence of any one of these violations can result in the temporary suspension of business operations. Property management units play a key role in ensuring continuous compliance and promptly updating practices in line with new regulations. 

Legal source: Decree 106/2025/ND-CP

Conclusion:  

This year marks a significant shift in the approach to and enforcement of standards, procedures, and responsibilities in fire prevention, fighting & rescue. Timely updating of regulations, reviewing organisational models, proactively coordinating with relevant authorities, and strengthening operational capacity not only ensures developers meet legal requirements but also enhances operational efficiency, mitigates risks, and fosters a safer, more sustainable living and working environment. 

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