Finin2min legal and practice guide • 15 October 2026

Project registration application — operative law and practical guidance

Section 4 calls for prescribed promoter details, recent-project history, approvals and commencement certificates, sanctioned plans, development facilities, location boundaries, proposed agreements and allotment data. Section 4(2)(l) contains important declarations on title, encumbrances, promised completion and the separate bank account. Inadequate disclosure and an outright lack of registration are different compliance failures.

Exceptions, state rules and legal consequences

Under section 5 the Authority is ordinarily to grant or reject a complete application within thirty days; statutory deemed-registration language must be read with the full procedure and does not permit reckless advertising on an unacknowledged application. Registration validity tracks the completion period declared for that project or phase. Section 6 extension is circumstance-specific and cannot be treated as an automatic annual renewal.

Practical application

The promoter should reconcile corporate name, land-owner and joint-development rights, unit inventory, approval version, lender charges and bank account undertakings across every upload. The filed declaration should have an internal legal signoff and immutable version trail, because the public project page becomes a buyer-facing representation.

How to prepare a compliant evidence trail

1. Prepare a document index matched to every section 4 disclosure
2. Reconcile approvals and encumbrances against title searches
3. File only after the statutory declaration and bank-account controls are internally approved
4. Check public project listing and issued number before any marketing release

Common errors to avoid

• Submitting an expired plan or unapproved layout as sanctioned
• Changing the completion date in advertising without portal records
• Confusing portal application reference with a granted registration

Decision point and edge case

A joint development arrangement deserves a separate landowner/promoter responsibility schedule. Identify which entity signs agreements, holds title, manages the 70% account and makes statutory declarations. If the landowner and developer have different roles on the portal and the agreement, determine whether each falls within the promoter definition; one person’s registration number does not remove another person’s duties.

Reader question

Is registration a government guarantee of construction quality? No; approval and disclosure are not warranties of title, structure, delivery or investment returns.

Primary legal sources

• India Code: RERA Act 2016
• MoHUA official RERA FAQs