Last reviewed: 25 September 2026. A MahaRERA project application is a disclosure dossier: land title, approvals, financial arrangements, timelines, and professional certificates that all must agree with each other. Files fail on internal contradictions more than missing pages. The legal base is sections 3 and 4 of the Real Estate (Regulation and Development) Act, 2016, read with the Maharashtra Real Estate (Regulation and Development) (Registration of Real Estate Projects, Registration of Real Estate Agents, Rates of Interest and Disclosures on Website) Rules, 2017. Since 11 May 2026 every application goes through MahaCRITI, MahaRERA's integrated portal. The ongoing compliance cycle lives in the promoter guide; this is the registration file itself.
- Section 3 bars advertising, marketing, booking or selling any unit in a project that is not registered.
- Section 3(2)(a) exempts a project on land of 500 sq m or less, or with eight or fewer apartments inclusive of all phases. MahaRERA Order No. 62/2024 reads these as alternative exemptions, so in Maharashtra registration is needed once a project crosses both limits. Our RERA applicability checker runs the test.
- Where a project is developed in phases, each phase is registered as a standalone project.
The promoter and project core
- Promoter constitution documents (COI/deed/partnership papers) and PAN
- Land title documents: ownership/development-agreement chain, 7/12 extracts, title report
- Encumbrance disclosures — honest ones; the register is public
- Sanctioned plans and commencement certificate from the planning authority
- Project details: phases, apartments/plots inventory, carpet areas, amenities
The financial and professional layer
| Item | Who signs | Notes |
|---|---|---|
| Form B declaration under section 4(2)(l) | Promoter, on affidavit | Title, encumbrances, completion period, and the undertaking to deposit 70% of realisations in a separate account and withdraw only in proportion to completion |
| Three designated bank accounts | Promoter and bank | Collection, separate (70%) and transaction (30%) accounts in one scheduled bank; see below |
| Form 1: architect's certificate | Project architect | Percentage of work completed against the sanctioned plans |
| Form 2: engineer's certificate | Project engineer | Cost of construction incurred and estimated, and quantities executed |
| Form 3: CA certificate | Practising chartered accountant | Cost incurred on land and construction, and the amount that may be withdrawn from the separate account; must reconcile with the books and with Forms 1 and 2 |
| Project cost estimates and funding plan | Promoter, supported by the certificates | Sources and schedule that survive quarterly comparison later |
| Agreement for sale and allotment letter formats | Promoter and advocate | Model documents under the rules, disclosed upfront |
The three-account structure
Section 4(2)(l)(D) of the Act requires 70% of amounts realised from allottees to go into a separate account, used only for land and construction cost. MahaRERA's bank account directions (Order No. 129/2024, in force from 1 July 2024) turn that into three accounts, all in the same scheduled bank:
| Account | What goes in | What comes out |
|---|---|---|
| RERA designated collection account | 100% of amounts realised from allottees | Transfers only to the separate and transaction accounts |
| RERA designated separate account | 70% of those realisations | Land and construction cost, in proportion to completion, against Forms 1, 2 and 3 |
| RERA designated transaction account | 30% of those realisations | Available to the promoter for other costs |
The account details are part of the application, so open all three before you file. Running collections through a general current account is the most common finding at the first Form 5 audit.
Fee basis
Rule 3(5)(i) of the Maharashtra rules sets the registration fee at Rs 10 per sq m of proposed land area, with a minimum of Rs 10,000 and a cap of Rs 10 lakh; plotted development pays Rs 5 per sq m. A 2,400 sq m residential building pays Rs 24,000; an 800 sq m commercial building pays the Rs 10,000 minimum. The portal computes the exact figure at application.
Worked timeline: a 2,400 sq m residential project
| Stage | Planning estimate |
|---|---|
| Title report, approvals check and document file | 2 to 6 weeks, depending on the title chain |
| Three bank accounts opened; Forms 1, 2 and 3 and Form B prepared | 1 to 2 weeks, alongside the file |
| MahaCRITI filing and fee payment of Rs 24,000 | A few days once the file is complete |
| Scrutiny and decision | 30 days from a complete application under section 5; each query cycle adds time |
| Marketing and bookings | Only after the registration number is issued, and it must appear on every advertisement |
The 30-day decision period is the only statutory figure in this table; the rest are planning estimates. The first stage slips most often, because title and approval gaps surface only when the file is assembled.
The CA's role after registration: Form 3 and Form 5
The CA certificate filed with the application is the first of many. Every withdrawal from the separate account needs a fresh Form 3, backed by the architect's Form 1 and the engineer's Form 2, so that money leaves only in proportion to completion. At year end, a practising CA reports on the project accounts in Form 5, filed within six months of the financial year end. Form 5 for FY 2025-26 is due by 30 September 2026. It checks that withdrawals matched the certificates, that the 70% was actually deposited, and that the three accounts were used as directed. A registration file whose opening cost figures do not match the books becomes a qualified Form 5 a year later.
Where files stumble
- Title chain gaps a scrutiny letter finds in one afternoon
- Timelines promised to RERA that contradict the sanctioned-plan reality
- CA cost figures unmoored from the promoter’s own books
- One bank account instead of three, or accounts split across banks
- Amenity promises inconsistent between brochure, plan and application
Frequently asked questions
Which projects need registration at all?
Section 3 of the RERA Act, 2016 requires registration before any advertisement, marketing or sale. Section 3(2)(a) exempts a project where the land does not exceed 500 sq m or the apartments do not exceed eight inclusive of all phases; MahaRERA Order No. 62/2024 reads these as alternative exemptions, so in Maharashtra registration is needed when both limits are crossed. Each phase is registered as a standalone project.
Can we register with approvals “in process”?
The application architecture expects sanctioned plans and commencement in place — the honest sequencing is approvals first; promises to the regulator are not placeholders.
Who signs the financial certificates?
The prescribed professionals: the architect in Form 1, the engineer in Form 2 and a practising chartered accountant in Form 3. Their numbers must reconcile with each other, because every withdrawal from the designated separate account later depends on exactly this trio.
How public is what we file?
Very — buyers and lenders read the portal. Draft every disclosure knowing it doubles as marketing diligence.
What changes for a redevelopment project’s file?
The title/consent layer thickens (society agreements, tenant consents) — same dossier logic, more chain to prove.
Our timeline slipped before registration completed. Restate?
File the timeline you can defend quarterly — RERA extensions exist but are earned, not assumed; the promoter guide covers the extension discipline.
Are the project bank accounts opened before or after registration?
Before. MahaRERA's bank account directions (Order No. 129/2024, in force from 1 July 2024) require three designated accounts in one scheduled bank: a collection account receiving 100% of allottee money, a separate account receiving 70%, and a transaction account receiving 30%. The account details go into the application, and collections belong there from the first rupee.
What follows immediately after registration?
The QPR clock and the annual Form 5 cycle — the registration certificate is the entry ticket to the compliance calendar, not the finish line.
What is the MahaRERA registration fee?
Under rule 3(5)(i) of the Maharashtra RERA Rules, 2017: Rs 10 per sq m of proposed land area, with a minimum of Rs 10,000 and a cap of Rs 10 lakh, or Rs 5 per sq m for plotted development. A 2,400 sq m residential project pays Rs 24,000. The portal shows the exact figure at application.
What is the difference between the CA's Form 3 and Form 5?
Form 3 is the CA certificate issued for each withdrawal from the separate 70% account, certifying cost incurred and the amount that may be withdrawn in proportion to completion. Form 5 is the annual report on the project accounts by a practising CA, filed within six months of the financial year end, confirming that withdrawals stayed within that proportion.
We assemble the dossier — title to certificates — reconcile the numbers across professionals, and carry the project into its quarterly cycle.
RERA Registration & ComplianceProject AccountingRequest a Scope DiscussionThis article is a general educational summary as on 25 September 2026 and is not professional advice or an assurance of any approval, registration or outcome — departmental decisions rest with the authorities on each case’s facts. Requirements change; verify current rules or discuss your specific case before acting.