Harun Raaj & AssociatesHarun Raaj & Associates
Audit & Assurance

RERA Project Audit & Utilisation Certificate

RERA Project Audit

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SCOPEConfirmed in writing

Regulatory Framework

RERA project audit centres on the escrow account mandate in Section 4(2)(l)(D) of the Real Estate (Regulation and Development) Act, 2016 (a central statute), which requires a promoter to deposit 70% of amounts realised from allottees for a project into a separate RERA escrow account, to be used only for that project's construction cost and land cost. Withdrawals from this account must be in proportion to the percentage of project completion and require certification confirming that withdrawn amounts have been utilised for the project — issued jointly by a practising engineer, a practising architect (who certify physical progress/completion percentage) and a practising Chartered Accountant (who certifies proportionate cost utilisation), before withdrawal is permitted.

The Act sets this 70%/proportionate-withdrawal framework centrally, but the specific certification forms, their numbering, and the annual reporting cycle are prescribed by each state's own RERA Rules framed under Section 84 of the Act, and these vary across states — for instance, some states require a periodic CA certificate at each withdrawal (commonly referenced as Form 3) plus a comprehensive annual statement of project accounts within six months of financial year-end (commonly referenced as Form 5), while others number or structure these certificates differently. Because the form references, exact filing deadlines and any state-specific escrow percentage variations (some state Authorities have permitted deviations from the standard 70% on a project basis) differ by the state RERA authority under which a given project is registered, this service is scoped against the specific state's notified RERA Rules and the project's state Authority registration, rather than a single uniform national form.

Overview

RERA project audit is the examination of a registered real estate project against the Real Estate (Regulation and Development) Act 2016 and the state RERA rules — the verification of the project disclosures against the actuals, the utilisation of the project funds from the escrow account, the compliance with the sanctioned plans and the specifications, the progress against the timelines, and the reporting obligations to the authority. The audit is the check that the project the developer sold is the project the developer is delivering.

The RERA project audit tests the developer's compliance with the Act's promises — the funds received from the buyers must be in the escrow account and used for the project, the construction must match the sanctioned plans and the advertised specifications, the progress must follow the registered timelines, and the disclosures and the reports must be current. The audit is the homebuyer's protection and the authority's verification, and its findings are the record the complaints and the enforcement are built on.

The cost of the audit findings is the compliance action: the utilisation discrepancies that the authority acts on, the specification deviations that the buyers enforce, the registration that is put at risk. The audit that finds the problems early is the audit that saves the project from the enforcement.

This service is for developers, the authorities and the stakeholders needing project audits. We audit the project against the RERA Act and the state rules — the escrow and the fund utilisation, the disclosures and the specifications, the progress and the timelines, the reporting — document the findings with the evidence, and produce the audit report with the compliance position and the remediation, so the project's RERA compliance is known and correct.

How It Works

  1. 1

    Project & Compliance Scope

    We define the audit scope against the RERA Act and the state rules.

    Harun Raaj & Associates does this3-5 days
  2. 2

    Escrow & Fund Utilisation

    We verify the escrow account and the utilisation of the project funds.

    Harun Raaj & Associates does this1 week
  3. 3

    Disclosures & Specifications

    We test the disclosures and the specifications against the actuals.

    Harun Raaj & Associates does this1 week
  4. 4

    Progress & Reporting

    We review the progress against the timelines and the reporting.

    Harun Raaj & Associates does this1 week
  5. 5

    Audit Report & Remediation

    We report the findings with the compliance position and the remediation.

    Harun Raaj & Associates does this1 week

Frequently Asked Questions

What RERA registrations and filings are ongoing obligations for a developer?
Real Estate (Regulation and Development) Act 2016: every commercial/residential project with area > 500 sq. m or >8 apartments must register with the state RERA authority before advertising or booking. Post-registration: quarterly updates of project status on the RERA portal (completion percentage, units sold, funds collected); annual Chartered Accountant's certificate on project finances by 30 September; and disclosure of any litigation, encumbrance, or material changes.
What is the RERA audit certificate and what does it cover?
Section 4(2)(l)(D) RERA and Rule 3 of state RERA rules require an annual CA certificate certifying: (1) total funds received from allottees in the financial year; (2) funds deposited in the designated separate project account (Section 4(2)(l)(D) mandates 70% of funds be deposited in the separate account); (3) utilisation of funds — construction cost, land cost; (4) funds withdrawn from the account and for what purpose. Separate account adherence is the core certification.
What is the 70% rule under RERA Section 4(2)(l)(D)?
70% of all amounts collected from allottees (for a specific project) must be deposited in a designated separate bank account — used only for that project's land acquisition and construction costs. The CA certifies compliance with this rule. Withdrawal is permitted only after certification by an engineer and CA of the work done proportional to the withdrawal. The remaining 30% can be used by the developer for other purposes (overhead, overheads, profit).
What are the penalties for RERA non-compliance?
Section 60: failure to register before selling/advertising — penalty up to 10% of estimated project cost. Section 61: non-compliance with orders of RERA authority — penalty up to 5% of estimated project cost per day. Section 63: non-compliance with the adjudicating officer's orders — up to 5% of cost per day. Section 66: deliberate failure to comply with RERA — imprisonment up to 3 years (for developer, individual officers). Homebuyers can also seek refund with interest (Section 18) for delayed possession.
What is the CA's role in RERA compliance for a builder?
The CA prepares and certifies: (a) the annual RERA certificate on separate account utilisation; (b) project-wise quarterly financial progress for the RERA portal; (c) cost-to-complete estimates and reconciliation with collections; (d) audit of whether the 70% fund has been maintained and withdrawals properly certified. For projects nearing completion, the CA assists in preparing the audited cost statement that triggers RERA authority satisfaction and enables transfer to the owners' association.

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