Developer & Promoter Turnkey Compliance
New Project Registration & Portal Management
Preparation and coordination support for project registration submissions and related portal records.
What this service involves
A project that falls within Section 3 must be registered before it is advertised, marketed, booked or sold. The application under Section 4 carries documents on the promoter, land, approvals, plans, a time schedule, financial details and the declaration regarding the designated account.
Preparation draws on all four disciplines. Chartered Accountants prepare the financial and bank-account declarations, advocates review title and legal documents, and engineers and architects prepare the certificates and plan details required. The final form is submitted by the promoter or an authorised user on the portal.
How is the registration boundary decided?
Identify the project or phase being offered before preparing the application. Section 3 treats each phase as a standalone project for registration, and the land, buildings, amenities and completion commitments should be consistent with that boundary. A project name used in marketing may cover a larger layout than the registration being sought. The application needs to make that difference understandable.
The applicability assessment should record the statutory exemption relied on, if any, and the facts supporting it. Do not assume that an existing approval, a redevelopment label or limited current sales removes the registration requirement. If registration is required, the marketing and booking team must understand that preparation or submission is not the same as registration. The engagement cannot authorise pre-registration activity prohibited by Section 3.
How are legal, technical and financial disclosures reconciled?
Use one master project schedule for the land description, promoter entities, unit inventory, carpet areas, approvals and proposed completion date. Compare title documents and development rights with the persons making the declaration. Compare sanctioned plans with the proposed inventory. Where approval extends only to a stage or portion, state that accurately rather than presenting a complete scheme as already sanctioned.
Section 4(2)(l)(D) requires the statutory separate-account arrangement and progress-linked certification. MahaRERA Order 56/2024 adds operational directions for designated accounts. The bank structure, estimated costs, professional certificates and promoter declarations should agree. Missing approvals or qualifications should be disclosed and addressed through the proper process, not hidden by changing numbers until the portal accepts them.
What happens between submission and ongoing compliance?
Keep the submitted application, annexures and acknowledgment as a versioned pack. Scrutiny responses should identify the observation, explanation and revised document without contradicting earlier disclosures. The promoter must authorise factual declarations and remain responsible for the information supplied. Credentials should be handled through an agreed secure access arrangement, not circulated casually among consultants.
After registration, verify the published page, registration period and downloadable documents. Set up the quarterly update, annual audit, certificate, advertising and change-control calendars immediately. Section 11 creates continuing duties; obtaining a number is not the end of the work. The service timeline separates internal preparation from Authority processing and does not promise a registration date or approval outcome.
Practical decision points
If the proposed unit inventory includes floors beyond the commencement permission supplied, the registration preparation note should identify the difference and the correct disclosure treatment. It should not alter the inventory merely to match an attachment without checking the underlying scheme, nor describe the missing permission as already obtained. Obtain the responsible architect’s explanation and the promoter’s factual instructions.
At handover, provide the final project boundary, approval register, inventory version, declaration pack and open-item schedule. The sales team should receive the actual registration and current disclosure parameters, not only a message that filing is complete. Finance should receive the account and certificate responsibilities, while the site team receives the progress-reporting requirements.
This division of information helps prevent a registration submission from becoming disconnected from the people who must keep the project record accurate after launch. Any unresolved condition should remain visible until evidence closes it.
Who needs it
Promoters planning a new project or a new phase.
Documents usually required
- Promoter identity and constitution documents
- Title documents and approvals
- Sanctioned plans and area statements
- Project schedule and cost estimates
- Bank account details for the designated account
- Architect, engineer and CA certificates in current formats
Step-by-step process
- Check whether and how Section 3 applies
- Prepare a document checklist
- Review title and approvals
- Prepare financial and technical certificates
- Complete the portal application for the promoter
- Respond to scrutiny observations
Typical timeline
Time depends on the readiness of documents and the Authority’s processing and scrutiny. Timing depends on the matter, document readiness and the relevant authority process; confirm the scope and timeline before engagement.
Delivered by
Chartered Accountant, Advocate, Engineer, Architect. The disciplines involved in a particular engagement are confirmed in the proposal.
The scope and responsible professional are identified in the engagement. Professional certificates are signed in the relevant professional or firm's own name. NXS48 is not an examination or certifying body.
Statutory and official references
- RERA Act, 2016, Section 3 (prior registration of real estate project)
- RERA Act, 2016, Section 4 (application for registration)
- RERA Act, 2016, Section 11 (functions and duties of promoter)
- Maharashtra Registration, Agent, Interest and Disclosure Rules, 2017: project/agent provisions and Rule 18 interest benchmark (read with amendments)
Last reviewed 2026-10-24. Owner-approved for publication. Section references and rates should be verified against the current Act, rules and circulars before reliance. This page is informational, not legal advice.
Frequently asked questions
Can a project be advertised before registration?
Section 3 requires registration before advertisement, marketing or sale of covered projects, subject to exemptions.
Who submits on the portal?
The promoter is responsible. We coordinate preparation and may assist with the portal as authorised.
Related services
Contact us for a tailored proposal
Tell us about the property, project or dispute. We scope the work first and prepare a proposal for it.