RERA Form A — Project Registration Walkthrough for Promoters (All States)

Registration is mandatory for any project where:

• The plot area exceeds 500 square metres, OR
• The number of apartments to be developed is more than eight (inclusive of all phases), OR
• A completion certificate is yet to be received as on 1 May 2017 (for legacy projects).

Key exclusions under Section 3(2):

• Renovation, repair or re-development that does not involve marketing, advertising, selling or new allotment of any apartment, plot or building.
• Projects where the area of land proposed to be developed does not exceed five hundred square metres and the apartments do not exceed eight.
• Government / parastatal housing.

Phased projects — each phase is a separate project for registration purposes under the proviso to Section 3(2). Promoters routinely attempt to under-register by collapsing phases; the State Authorities have consistently rejected this.

Timing — registration must be obtained before any advertising, marketing, booking, sale or offer for sale of any plot, apartment or building (Section 3(1)). The penalty for non-registration under Section 59 is up to 10% of the estimated cost of the project, and continued non-registration can attract imprisonment up to three years. Several State Authorities have begun suo motu actions based on Google search ads and Facebook campaigns where the project name is unregistered.

Form A under Rule 3 of the State RERA Rules has roughly 24 sections. The fields that get registrations rejected:

Promoter details (Section 1)

• Full legal name of the promoter entity (LLP / Pvt Ltd / partnership / individual).
• CIN / LLPIN / PAN.
• All directors / partners / promoters with their PAN, address, and details of any criminal proceedings or business defaults (Section 4(2)(l)(iv)) — this is the field most promoters under-disclose; the Authority can cancel registration under Section 7(1)(c) for false disclosure.

Project details (Section 2)

• Project name (must match every brochure, ad and Hoarding).
• Project type — residential / commercial / mixed.
• Total plot area, FSI sanctioned, total built-up area, carpet area to be sold.
• Phases — each phase is a separate registration.

Land details (Section 3)

• Title documents — the chain of title showing the promoter's right to develop. If the promoter is a developer under a Joint Development Agreement, the JDA must be attached.
• Encumbrance certificate for 30 years (most states; UP requires 12).
• Litigation status — any pending suit, attachment, etc.

Sanctions and approvals (Section 4)

• Building plan sanction with all annexures.
• Layout plan sanction.
• Environmental clearance (if applicable).
• Fire NOC, AAI NOC (if near airport), heritage NOC (if applicable), CRZ NOC (if coastal).

Project schedule and financials (Section 5)

• Quarter-wise project schedule for the entire project.
• Estimated cost of the project (this is the basis for the 1% / 10% / etc. fee calculations).
• Separate bank account for the project under Section 4(2)(l)(D) — 70% of the amounts received from allottees must be deposited here. The bank account number and IFSC must be filled in Form A. This is the field that has caused the most disputes — the account must be in a scheduled commercial bank, not a co-operative bank, and must be exclusive to the project.

Allottee information disclosures (Section 6)

• Total apartments to be sold, sold so far, available.
• Carpet area definitions exactly per Section 2(k).
• Pricing structure — per-sq-ft basis.

Fees vary enormously by state. The most common formula is a per-sq-metre fee with a minimum and maximum, charged on plot area for residential and on total area for commercial. Approximate 2026 rates for major states:

• Maharashtra (MahaRERA) — Residential: ₹10 per sq m of land if built-up area ≤ 1000 sq m, ₹50 per sq m thereafter; Maximum ₹10 lakhs.
• Uttar Pradesh (UP RERA) — ₹500 per apartment, capped at ₹10 lakhs for projects > 1000 sq m.
• Karnataka (RERA Karnataka) — Residential: ₹5 per sq m if area ≤ 1000 sq m, ₹10 per sq m for 1001-10000 sq m, ₹20 per sq m beyond, max ₹10 lakhs.
• Tamil Nadu (TN RERA) — Residential: ₹5 per sq m up to 1000 sq m, then ₹10 per sq m; max ₹10 lakhs.
• Telangana (TS RERA) — ₹2 per sq m up to 1000 sq m, then ₹5 per sq m up to 5000 sq m, then ₹10 per sq m; max ₹10 lakhs.
• Haryana (HRERA) — Residential: ₹10 per sq m up to 1000 sq m, ₹50 per sq m beyond; max ₹10 lakhs.
• Delhi (DDA acting as RERA Authority) — ₹10 per sq m up to 1000 sq m, then ₹100 per sq m, max ₹10 lakhs.
• Gujarat (GujRERA) — ₹5 per sq m up to 500 sq m, ₹10 per sq m for 501-1000 sq m, ₹50 per sq m beyond; max ₹10 lakhs.

Commercial project fees are typically 2x to 5x the residential fee. Always verify the latest rate from the State RERA's fee notification before filing — most states have revised fees in 2023-25.

From 5+ years of State Authority practice, the most common rejections:

1. Title chain not clear for 30 years — gaps in mutation, unregistered family settlements, ancestral property partitions not effected. Fix by getting a title certificate from a senior advocate and supplementary affidavits.
2. Project name conflicts with another registered project in the same area — Authorities reject to prevent confusion. Change the name.
3. Phase boundaries not clear on the layout — Authority asks for a clarificatory affidavit naming exactly which plot numbers / tower numbers fall in this phase.
4. Sanctioned plan and proposed sale plan inconsistent — e.g. plan shows 3BHK apartments but the brochure offers studios. Reconcile.
5. Bank account is not exclusive to the project — Authority asks for a fresh designated account.
6. Project schedule inconsistent with approval validity — if the building plan validity expires before the proposed possession date, the Authority demands an extended approval or a shorter possession commitment.
7. Promoter director undisclosed criminal record found on database checks — the Authority either rejects or imposes additional conditions.
8. JDA terms not consistent with title — particularly common in Karnataka/Bengaluru where multi-party JDAs are common.

Most rejections come with a 'reasons letter' and an opportunity to cure within 30 days. Use that window — re-applying from scratch loses the filing fee in most states.