RERA Project Registration Process, Documents and Timelines

RERA Project Registration in Maharashtra

You cannot advertise, market, book, sell or offer for sale any unit in a project that requires registration until the registration is granted. Not after applying — after it is granted. Developers who put up a hoarding or take a soft booking during the application period have already contravened Section 3, and the penalty is calculated on project cost.

N D Savla & Associates prepares and files RERA project registration applications for developers across Maharashtra. The work that matters is done before submission: confirming the threshold applies, deciding how the project is phased, and settling the completion date and cost estimate that will bind you for the project life. Registration is the entry point to the wider RERA compliance obligations that follow.

This page covers which projects require registration, the documents and declarations needed, the fee structure, the application process and realistic timelines. If you are unsure whether your project is above the threshold, the applicability section answers that first.

Which Projects Need RERA Registration?

Section 3 of the Real Estate (Regulation and Development) Act, 2016 requires registration of any real estate project where the land proposed to be developed exceeds five hundred square metres, or where more than eight apartments are proposed to be developed, inclusive of all phases.

Both limbs matter, and it is a common error to read them as cumulative. A project on land above five hundred square metres requires registration even with fewer than eight units, and a project with more than eight units requires registration even on a smaller plot. Either condition triggers the obligation.

Certain projects fall outside: those where the promoter has received a completion certificate before the Act commenced, renovation or repair work that does not involve marketing or new allotment, and projects below both thresholds. The exclusion for completed projects is narrower than developers often assume, since a project without a completion certificate remains an ongoing project regardless of how far construction has progressed.

What Documents Are Required for Registration?

The application is document-heavy, and gaps in title or approvals are the usual cause of delay.

Note: the Form B declaration is made on affidavit by the promoter and covers title, encumbrance, the completion timeline and the designated account undertaking. It is a sworn statement, not a form-filling exercise, and it is the document most often relied on against a promoter later.

Who Applies and When?

The promoter applies, and the timing question determines whether the application is straightforward or complicated.

New Projects Before Launch

For a project not yet marketed, registration must be obtained before any advertising, marketing, booking or sale. This is the cleanest scenario: approvals are current, no allottees exist, and the declared timeline can be set against a genuine construction programme rather than reverse-engineered from commitments already made to buyers.

Phased Developments

Large developments are registered phase by phase, each phase carrying its own registration number, designated account, completion date and reporting cycle. Phase boundaries should reflect how construction and sales will genuinely proceed, since redrawing them afterwards requires a modification application and is not always granted.

Ongoing Projects Without Completion Certificate

Projects under construction when the Act came into force, and which had not received a completion certificate, required registration as ongoing projects. Where such a project was never registered, the position needs regularising, and the exposure includes the period of non-registration rather than only the position going forward.

Joint Development and Redevelopment Arrangements

Where land is owned by one party and developed by another, the question of who is the promoter has to be settled before application, since the promoter carries the statutory obligations. In society redevelopment the development agreement, allotment to existing members and rights of new purchasers all need to be consistent with what will be disclosed on the portal.

How Did Project Registration Come About?

Compulsory registration of real estate projects was the central mechanism the 2016 Act introduced, and it addressed a specific, long-standing failure.

Before 1991: Disclosure Without a Register

The Maharashtra Ownership Flats Act, 1963 required a promoter to disclose particulars and execute an agreement before taking more than a fifth of the price, but there was no central register of projects and no authority verifying that the disclosed particulars were true. A buyer could not check whether title was clear or whether approvals existed, and the only remedy for a false disclosure was civil litigation.

1991 to 2016: Pre-Launch Selling and Information Asymmetry

The post-liberalisation construction boom normalised selling before approvals were in place. Pre-launch bookings funded land acquisition, project timelines were marketing positions, and money collected on one project routinely financed another. Because no register existed, a buyer had no means of verifying any of it, and defaults surfaced only when possession failed to arrive.

2016: Registration Becomes the Gateway

The Act made registration compulsory under Section 3 above prescribed thresholds and set out in Section 4 what the application must contain — title documents, approvals, the declared completion date, project cost, and the Form B declaration on affidavit. Registration became the precondition for any marketing activity, which removed the pre-launch model entirely for projects within scope. MahaRERA began registering projects from mid-2017.

Where Things Stand Now

Applications, fee payment and grant all run through the authority online system, and every registered project carries a public page showing approvals, timelines, promoter details and quarterly progress. MahaRERA has issued detailed orders on registration requirements, on the treatment of lapsed registrations and on projects that failed to register when required. Buyers and lenders check the register as a matter of routine, so registration has become commercially necessary as well as legally required.

How Does the Registration Process Work?

We run registration in eight steps. Where documents and approvals are in order the process typically completes within thirty to sixty days.

1. Applicability and Threshold Assessment — We confirm whether the project crosses either threshold — land above five hundred square metres or more than eight apartments across all phases — and whether any exclusion applies. Getting this wrong in either direction is expensive.
2. Phasing Decision — For larger developments we settle how the project will be divided into phases, since each phase carries its own registration, designated account, timeline and reporting. This decision constrains everything afterwards and is difficult to revisit.
3. Title and Approval Verification — Title documents, the advocate title certificate, encumbrance position, commencement certificate and sanctioned plans are checked for consistency with each other and with the project as it will actually be built.
4. Project Cost Estimation — Land cost and construction cost are built up realistically, since the estimate drives the registration fee, the designated account computation and the withdrawal certification for the project life. An estimate prepared to minimise fees creates problems at every subsequent certification.
5. Completion Timeline Determination — The completion date is fixed against a genuine construction programme with sensible allowance for approvals and contingency. This is the single most consequential declaration in the application, because Section 18 liability runs from it.
6. Declaration and Document Preparation — The Form B declaration on affidavit, the designated account undertaking, the carpet area schedule, the draft allotment letter and the agreement for sale in prescribed form are prepared and reconciled against one another.
7. Online Application and Fee Payment — The application is filed on the authority portal using the promoter digital signature, with documents uploaded in prescribed formats and the fee paid, which is computed on area at the rates set under the state rules.
8. Query Response and Grant — Queries raised by the authority are answered with supporting evidence, and on approval the registration number and certificate are issued. Only at that point can marketing and sales begin.

Filing requires the promoter digital signature certificate, and the cost estimate is best prepared as a proper financial model rather than a summary sheet, since it will be referenced at every withdrawal certification for years.

Warning: no advertisement, marketing, booking, sale or offer for sale is permitted until registration is granted — not from the date of application. Soft launches and pre-registration bookings are contraventions of Section 3 and attract penalty of up to ten percent of estimated project cost.

How Does Registration Differ by Project Type?

The application is common. What differs is where the difficulty concentrates.

Single-Building Residential Projects

The most straightforward category, with one registration, one timeline and one designated account. The main issues are usually title chain completeness and ensuring the carpet area schedule reconciles exactly with the sanctioned plan, since discrepancies here surface later as buyer claims.

Large Phased Townships

Phasing dominates. Each phase needs its own registration, and common amenities serving multiple phases have to be allocated deliberately, with clarity on which phase carries the obligation to deliver them and by when. Because phases run on different timelines, the later ones frequently need extension applications as the development progresses.

Redevelopment and Society Projects

The development agreement with the society, the entitlement of existing members, corpus and transit rent arrangements, and the rights of new purchasers must all sit consistently with the RERA disclosures. Determining who is the promoter — the society, the developer or both — needs to be settled before application rather than left ambiguous.

Plotted Development and Commercial Projects

Plotted developments are covered where thresholds are crossed, with the area computation working differently from an apartment project. Commercial projects register on the same basis as residential, which promoters occasionally miss. In both cases the carpet area definition and the prescribed agreement form apply.

Why Choose N D Savla & Associates for Project Registration?

These are the five reasons developers use us for the application.

• The declarations are treated as commitments, not paperwork. The completion date and cost estimate bind you for years, and we advise on them before they are filed rather than defending them afterwards.
• Cost estimate built properly by chartered accountants. It drives the fee, the designated account computation and every withdrawal certification, so an estimate prepared carelessly creates recurring problems.
• Phasing structured with the full project in view. Phase boundaries constrain funding, timelines and reporting for the entire development and are difficult to change once registered.
• Documents reconciled before submission. Title, approvals, area schedules and draft agreements are checked against each other, since internal inconsistency is the most common reason an application stalls.
• Continuity after grant. The same team handles quarterly updates, withdrawal certification and annual audit, so what was declared at registration and what is reported afterwards stay consistent.

Applications are made to and granted by the Maharashtra Real Estate Regulatory Authority, and we work from the requirements, formats and orders published at maharera.maharashtra.gov.in, so the application reflects current practice rather than the position when the Act was first notified.

Frequently Asked Questions About Project Registration