Who it applies to
Every promoter of a MahaRERA-registered project, for as long as allottee money is collected and spent. Lenders and co-promoters rely on the same certificates.
Legal basis
| Provision | What it requires |
|---|---|
| Section 4(2)(l)(D) | 70% of amounts realised from allottees deposited in a separate account in a scheduled bank, used only for land and construction cost |
| First and second provisos | Withdrawals in proportion to completion, certified by the project's engineer, architect and a practising CA |
| Third proviso | Accounts audited within six months of each FY end; statement of accounts certified by a practising CA |
| MahaRERA (General) Regulations 2017, Regulation 4 | Form 5 signed by the promoter's statutory auditor; Form 3 for withdrawals signed by a different CA |
| MahaRERA Order No. 56/2024 | Collection, separate and transaction accounts in one scheduled bank, 70% auto-swept to the separate account; for projects registered on or after 01-07-2024 |
| MahaRERA Order No. 61/2024 | Account obligations rest with the declared promoter only |
Projects registered before 01-07-2024 continue with the single designated separate account unless MahaRERA directs otherwise.
Documents required
Bank statements of all designated accounts, books of account for the project, cost records with invoices and contracts, land and approval cost workings, estimated cost and its revisions, loan sanction and drawdown details, and the architect's and engineer's certificates (Forms 1 and 2) for the period.
Timeline
| Obligation | When | Signed by |
|---|---|---|
| Form 3 for withdrawal from the separate account | Before each withdrawal | Practising CA other than the statutory auditor |
| Form 3 with quarterly update | With each QPR (20 Jul, 20 Oct, 20 Jan, 20 Apr) | Practising CA other than the statutory auditor |
| Form 5 annual report on statement of accounts | Within six months of FY end (30 Sep) | Promoter's statutory auditor |
| Change of designated bank | Before the change | Prior MahaRERA approval |
Consequences of non-compliance
Excess or unsupported withdrawals are visible in Form 5 and on the public project page.
Contravention of Section 4 provisions can attract a penalty under Section 61 of up to 5% of the estimated project cost, and false information can lead to revocation of registration under Section 7.
How we help
- Form 3 certificates with UDIN, for withdrawals and quarterly updates, where we are not the statutory auditor
- Form 5 where we are the promoter's statutory auditor; support to the auditor and reconciliations where we are not
- Reconciliation of collections, auto-sweep transfers and withdrawals across the designated accounts
- Project cost tracking: land and construction cost incurred against estimate
- Review of loan drawdowns and their use for construction
- Early identification and correction of excess withdrawal or under-deposit
- Applications for change of designated bank
Deliverables: Signed certificates, reconciliation working papers, and a quarterly fund-utilisation summary for management.
Unsure whether your withdrawals reconcile?
Request a consultation for a review of your designated accounts before the next certificate.
Content as at 27-10-2026. General information only, not professional advice; see our Disclaimer.