Every MahaRERA project has to file a Quarterly Progress Report (QPR). The one for July to September was due on 20 October, so most developers have just finished it. That makes November a good time to review your project accounts, before the next quarter ends.
The December quarter closes on 31 December, and its QPR is due on 20 January. Checking your accounts now gives you time to fix any mistakes calmly, instead of during the filing rush.
This checklist outlines the key areas developers should review this month.
1. Check Your 70% Deposits Against Collections
Under Section 4(2)(l)(D) of the RERA Act, 70% of what you collect from allottees has to go into the separate designated account of that project. Pull your collection register for July to September and match it with what actually reached the bank.
The usual gaps are:
- Instalments that landed in the operating account by mistake
- Receipts booked in the ledger but not yet showing in the bank
- Transfers made late, after the quarter had closed
Also look at the account title and confirm that no lender has registered a lien or set-off against it. The law does not allow that on this account.
Tip: Fix any shortfall now with a clean paper trail. It is far easier than explaining it in January.
2. Match Every Withdrawal to Form 1, Form 2 and Form 3
Money comes out of the designated account only against three certificates: the architect’s Form 1, the engineer’s Form 2 and the CA’s Form 3. The percentage of completion decides how much you can take out. So the total withdrawn till date should never cross what your latest Form 3 supports.
Check these three things:
- The certificate date is earlier than the withdrawal date
- The amount withdrawn sits within the Form 3 limit
- Each payout has a matching vendor invoice and ledger entry
If you withdrew nothing during the quarter, you still have to self-certify the amount deposited and upload it on the portal. This one gets forgotten more than you would think.
3. Reconcile the Bank Statement With Your Books
Do this month by month and not in one sitting. Look for project expenses paid from the wrong account, and for entries in the designated account that have no project expense behind them. Both look bad in a scrutiny.
Timing matters here. MahaRERA looks at when money was spent and who received it, so a vendor payment should sit in the same period as the Form 3 that covered it. Backdated invoices will stand out quickly.
Tip: Keep the invoice, GST details and payment proof together for every withdrawal. Your CA will thank you.
4. Keep Pass-Through Charges in a Separate Account
Amounts you collect from buyers only to pass on, such as GST, stamp duty and registration charges, should not be mixed into the designated account. Maintain a different account for these and keep its records clean.
If you find pass-through money sitting in the RERA account, move it out with proper documentation and note it in your working papers. Do it now so the December reconciliation starts fresh.
5. Confirm Form 5 Is Filed and Ties to Your Form 3s
Form 5 is the annual statement of accounts certified by a practising CA. It is due within six months of the financial year end, so the one for FY 2025-26 should already be on the portal.
Open it and compare the totals with the four quarters of Form 3 for that year. If Form 5 shows withdrawals above the percentage of completion, that excess will need to be explained and corrected. Better you find it than the Authority does.
6. Look at Your Project Page the Way a Buyer Would
Your quarterly forms are public. Buyers and their advisors can see the architect, engineer and CA certificates quarter after quarter, along with booked units and the declared completion date. MahaRERA has openly asked buyers to verify project details on its portal before investing.
Open your own project page and check:
- Booked units match your sales records
- Completion date is still valid, or an extension is already applied for
- The MahaRERA QR code on your ads leads to the right page
7. Plan the December Quarter Now
Book your architect and engineer for a site visit in the third week of December, so Form 1 and Form 2 are ready early. Ask your accounts team to close vouchers every month. Set an internal deadline of 10 January for the CA to receive all data, which leaves ten days before the 20 January due date.
It sounds boring, and it is. It also works.
How Professional Guidance Can Help
RERA accounting has many moving parts, and one mismatch can hold up an entire QPR. A second pair of eyes, well before the deadline, saves a lot of stress.
At JD Shah Associates, we help developers with:
- MahaRERA registration and project compliance
- Form 3 and Form 5 certification
- Designated account reconciliation and withdrawal review
- Replies to show-cause notices and compliance gaps
Final Thought
Most RERA trouble starts small. A late transfer here, a missing invoice there. A one-hour review each November keeps those small things from piling up before the year ends.
If you want help with your MahaRERA project accounts, Form 3 certification or quarterly compliance, the team at JD Shah Associates is happy to take a look.
