Introduction
A certificate issued under RERA is not a single document — it is a small family of professional certificates that keep a real estate project financially honest. The most important ones, issued by a Chartered Accountant (CA), are Form 3 (the certificate that lets a promoter withdraw money from the project’s separate bank account) and Form 5 (the annual report on the statement of accounts).
These certificates exist because of one simple promise RERA makes to home buyers: the money you pay for a flat will be spent on your project, not diverted elsewhere. This guide — written from the perspective of a practicing Chartered Accountant — explains what each certificate means, who can issue it, the exact legal provisions, the documents required, a sample Form 3 format, and answers to 40+ questions.
Whether you are a promoter, company director, banker, lender, NRI investor, student, or tax consultant, this guide will make RERA certification clear.
What Is a Certificate Under RERA?
The Real Estate (Regulation and Development) Act, 2016 (RERA) requires a promoter to deposit a large part of buyer money into a separate, ring-fenced bank account. To put money in — and especially to take money out — the promoter must produce certificates from independent professionals. These are the “certificates under RERA”.
The CA’s certificates (the focus of this guide)
- Form 3 — CA’s Certificate for Withdrawal: certifies the estimated project cost, the cost actually incurred, the percentage of completion, and the amount that may be withdrawn from the separate account in proportion to that completion.
- Form 5 — Annual Report on the Statement of Accounts: issued by the CA who is the statutory auditor of the promoter, certifying that the money collected for the project was used only for that project, and that withdrawals matched the percentage of completion.
The architect’s and engineer’s certificates
- Form 1 — Architect’s Certificate: certifies the percentage of physical work completed as per the sanctioned plan.
- Form 2 / 2A — Engineer’s Certificate: certifies the cost incurred on construction and the quality of work.
- Form 4 — Architect’s Certificate on Completion: issued when the project is completed.
Note on form numbers: Form numbers above follow MahaRERA (Maharashtra). The requirement is common across India because it flows from the central RERA Act, but each state notifies its own rules and may number or format the forms differently. Always use your own state RERA authority’s prescribed format.
Purpose of a Certificate Under RERA
The certificate serves financial-discipline and consumer-protection goals:
- Ensures 70% of buyer money is ring-fenced for the project’s land and construction cost
- Allows withdrawals only in proportion to actual project completion
- Prevents diversion of one project’s funds into another project
- Gives the scheduled bank a clear, certified basis to release money
- Provides the RERA authority and allottees with an audit trail of fund usage
- Confirms, annually (Form 5), that collections were used only for that project
- Builds trust for bankers, lenders, and NRI/foreign investors evaluating the project
Why Is a Certificate Under RERA Required?
Different stakeholders rely on the certificate for different reasons:
| Stakeholder | Why They Need It | Typical Timing |
|---|---|---|
| Promoter / Developer | To legally withdraw funds from the separate account | At each withdrawal |
| Scheduled Bank | To release money only against certified completion | Before each release |
| RERA Authority | To verify funds are used for the project and to allow registration | Registration & annually |
| Allottees / Buyers | Assurance their money is being used for their flats | Throughout the project |
| Lenders / Banks (project finance) | Independent check on project cost and progress | During the loan tenure |
| NRI / Foreign Investors | Due diligence on financial discipline of the project | Before investment |
| Statutory Auditor | Annual certification of project fund usage (Form 5) | Within 6 months of FY end |
Who Can Issue a Certificate Under RERA?
🎓 Chartered Accountant (CA) — Form 3 & Form 5
Only a Chartered Accountant in practice, holding a valid Certificate of Practice (COP) from ICAI, can issue Form 3 (withdrawal) and Form 5 (annual report). Form 5 is specifically issued by the CA who is the statutory auditor of the promoter’s enterprise.
📐 Architect — Form 1 & Form 4
A registered architect certifies the percentage of work completed (Form 1) and the completion of the project (Form 4).
🏗️ Engineer — Form 2 / 2A
A qualified engineer certifies the cost incurred on construction and the quality of materials and work.
📋 Cost Accountant (CMA) & 🖊️ Company Secretary (CS)
Cost Accountants and Company Secretaries are not authorised to issue the RERA Form 3 or Form 5. These are reserved for a practicing Chartered Accountant. (A CS may assist with secretarial/registration compliance, and a CMA with cost records, but not with these certificates.)
Important: The bank will release money from the separate account only when Form 3 is submitted together with the architect’s Form 1 and the engineer’s Form 2. The three certificates are read together, and the CA’s certificate is built on top of the engineer’s and architect’s certificates.
Legal Provisions and Applicable Laws
| Law / Provision | Relevance to the RERA Certificate |
|---|---|
| RERA, 2016 — Section 4(2)(l)(D) | The core provision: 70% of allottee money in a separate account; withdrawal only in proportion to completion, certified by engineer, architect and CA. Its third proviso requires annual audit by a CA within 6 months of FY end (Form 5). |
| RERA, 2016 — Section 3 & 4 | Registration of the project and disclosures, including project cost estimates that the CA certificate ties back to. |
| RERA, 2016 — Section 11(1)(e) | Quarterly updation of project status on the RERA web page. |
| State RERA Rules (e.g., MahaRERA Rule 5, 2017) | Prescribe the form numbers and formats (Form 1, 2, 3, 4, 5) and the withdrawal mechanism. |
| Companies Act, 2013 | Where the promoter is a company/LLP, statutory audit underpins the figures certified in Form 5. |
| Income Tax Act, 1961 | Project income, books of account, tax audit (Section 44AB) and ITR support the financial data. |
| GST Law (CGST Act, 2017) | GST on under-construction units; indirect taxes may be kept outside the separate account per state circulars. |
| Ind AS 115 / ICAI Guidance Note on Real Estate | Revenue recognition and cost measurement principles relied on while certifying. |
| FEMA, 1999 & RBI norms | Relevant where NRIs/foreign investors fund the project (FDI in construction development). |
| SEBI (REIT) Regulations | Relevant where the project sits within a listed real estate investment trust structure. |
| Chartered Accountants Act, 1949 | Governs the CA’s conduct, due diligence and liability while certifying. |
70% of amounts realised from allottees → Separate Bank Account → withdraw only in proportion to % completion (Sec 4(2)(l)(D))
When Is a Certificate Under RERA Required?
| Situation | Certificate Required? | Notes |
|---|---|---|
| Project Registration with RERA | Yes (Form 3) | CA certificate of estimated project cost / declaration |
| Withdrawal from Separate Bank Account | Yes (Form 1 + 2 + 3) | Each withdrawal, in proportion to completion |
| Annual Compliance | Yes (Form 5) | Within 6 months of every financial year end |
| Quarterly Project Update | Often | Architect/engineer certificates updated; CA cert maintained |
| Bank / Project Loan Disbursement | Yes | Lender relies on certified cost & progress |
| Project Completion | Yes (Form 4 by architect) | Final certification on completion |
| New Project with No Collections Yet | Not yet | No allottee liability means no withdrawal certificate needed |
Who Needs a Certificate Under RERA?
- Individual promoters and proprietors developing a registered project
- Partnership firms undertaking real estate development
- LLPs registered as promoters
- Companies and their directors developing housing/commercial projects
- Landowners and developers under Joint Development Agreements (JDAs)
- Trusts and societies developing real estate (where applicable)
- NRIs and foreign investors funding Indian real estate projects
- Startups in proptech / real estate development raising buyer funds
- Bankers and lenders (as users who rely on the certificate)
- Tax consultants and CAs advising promoters on RERA compliance
Documents Required for a Certificate Under RERA
A comprehensive checklist the CA will typically need:
Project & Legal Documents
- RERA registration certificate and registration number
- Sanctioned building plan and commencement certificate
- Title documents / development agreement / JDA (if any)
- Estimated cost of the project (land cost + construction cost)
- Architect’s certificate (Form 1) and Engineer’s certificate (Form 2)
Financial & Banking Documents
- Bank statements of the separate (70%) account and the collection account
- Project-wise books of account and trial balance
- Allottee-wise collection ledger / receipts
- Cost-incurred ledgers (land, materials, labour, approvals, overheads)
- Details of amounts already withdrawn from the separate account
- Audited financial statements of the promoter (for Form 5)
- GST returns and tax records relating to the project
Information Required by the Chartered Accountant
Beyond documents, the CA needs the promoter to disclose and confirm:
- The purpose (registration, a specific withdrawal, or annual Form 5)
- The exact estimated cost of the project and its basis
- The total amount realised from allottees to date
- The cost incurred to date, with supporting bills/vouchers
- The percentage of completion as certified by the engineer and architect
- Amounts already withdrawn from the separate account
- Whether any project funds were used for non-project purposes (a red flag)
- Details of joint development / revenue sharing, if any
The CA usually obtains a management representation / declaration from the promoter confirming the data is complete and true before issuing the certificate.
Step-by-Step Process of Issuing a Certificate Under RERA
- Promoter Approaches the CA
The promoter states the purpose — registration, a withdrawal, or the annual Form 5 — and shares the RERA registration details. - Collection of Documents
The CA gathers project documents, bank statements, books of account, the allottee ledger, and the architect’s (Form 1) and engineer’s (Form 2) certificates. - Verification of Project Cost & Collections
The CA verifies the estimated project cost, the cost incurred to date, and the amounts realised from allottees, cross-checking the separate-account bank statements. - Computation of Percentage of Completion
The CA computes the proportion of cost incurred to total estimated cost and reconciles it with the engineer’s/architect’s certified completion. - Calculation of Withdrawable Amount
The amount permitted to be withdrawn from the separate account is calculated in proportion to completion, less amounts already withdrawn. - Promoter Declaration
The promoter signs a representation confirming completeness and accuracy of the information provided. - Issue of Certificate with UDIN
The CA issues Form 3 (or Form 5) on the firm’s letterhead, signed and sealed, with membership number, FRN, date and UDIN. Both CA and promoter sign Form 3. - Submission to Bank / Upload to RERA
Form 3 (with Form 1 & 2) goes to the scheduled bank for release of funds; Form 5 is uploaded to the RERA portal within the annual timeline.
Sample Format of a Certificate Under RERA (Form 3)
Below is an illustrative specimen of a Form 3 withdrawal certificate. Figures are made-up and rounded. Actual format must follow your state RERA authority’s prescribed Form 3.
SPECIMEN — FOR ILLUSTRATIVE PURPOSES ONLY
M/s. Sharma & Associates
Chartered Accountants
Firm Reg. No. 012345N | Mumbai – 400001
Tel: +91 98765 43210 | Email: info@sharmaandassociates.inFORM 3 — CERTIFICATE FOR WITHDRAWAL
[See Section 4(2)(l)(D) of RERA, 2016 & State RERA Rules]Ref. No.: SA/RERA/2026/0087 Date: 10 June 2026
This is to certify that we have verified the books of account, bank statements of the separate account, and the cost records of the real estate project “Green Meadows – Phase I”, RERA Registration No. P51700000000, being developed by M/s. ABC Developers LLP.
Based on our verification and on the certificates of the Engineer (Form 2) and Architect (Form 1), the position as on 31 May 2026 is as follows:
Particulars Amount (₹) Estimated cost of the project (land + construction) 50,00,00,000 Cost incurred on the project to date 20,00,00,000 Percentage of completion (cost incurred / estimated cost) 40% Amount realised from allottees to date 30,00,00,000 Amount permitted to be withdrawn (in proportion to completion) 12,00,00,000 Amount already withdrawn from separate account 8,00,00,000 Net amount that can be withdrawn now ₹ 4,00,00,000 Note: This certificate is based on records and information furnished by the promoter and on the Engineer’s and Architect’s certificates, verified to the best of our ability. It is issued solely for withdrawal of funds from the separate bank account of the above project under Section 4(2)(l)(D) of RERA, 2016, and should not be used for any other purpose.
For M/s. Sharma & Associates
CA Ankit Sharma
M. No. 123456 | FRN: 012345N
Place: Mumbai | Date: 10.06.2026
UDIN: 26123456AAAABB1234Signed by Promoter: ____________________ [Firm Seal]
SPECIMEN — FOR ILLUSTRATIVE PURPOSES ONLY
⚠️ Note: This specimen is illustrative only. The actual Form 3 must follow the exact format notified by your state RERA authority, must be signed by both the CA and the promoter, and must carry a valid UDIN.
How a CA Verifies the Information
Verification is the heart of RERA certification. A CA typically checks:
| Item | Verification Method |
|---|---|
| Estimated project cost | Sanctioned plan, cost estimates, comparison with RERA-declared cost and Form 1 / Form 2 |
| Cost incurred to date | Bills, vouchers, cost ledgers, contractor running bills, engineer’s Form 2 |
| Percentage of completion | Cost-to-cost computation reconciled with the architect’s Form 1 |
| Collections from allottees | Allottee ledger, receipts, agreement values, collection-account statements |
| Separate (70%) account | Bank statements; confirm only project payments and proportionate withdrawals |
| Amounts already withdrawn | Prior Form 3s, bank withdrawals from the separate account |
| Fund diversion check | Scan for non-project payments; flag any diversion |
The CA applies professional scepticism and may refuse to certify if records are inconsistent, the architect’s/engineer’s figures do not reconcile, or funds appear diverted.
Common Reasons for Rejection
| # | Reason | How to Avoid |
|---|---|---|
| 1 | Form 3 cost figures do not match Form 2 (engineer) or the RERA-declared cost | Reconcile all three before submission; standardise the cost estimate |
| 2 | Certificate not in the state-prescribed format | Always use your own state RERA’s Form 3 format |
| 3 | Missing UDIN, FRN, or membership number | Ensure full CA credentials and a valid UDIN are printed |
| 4 | Promoter’s signature missing on Form 3 | Both CA and promoter must sign |
| 5 | Withdrawal exceeds the proportion of completion | Limit the withdrawable amount strictly to % completion |
| 6 | Project funds used for non-project / other-project expenses | Maintain a clean, project-only separate account |
| 7 | Form 5 not filed within 6 months of FY end | Calendar the annual audit deadline |
| 8 | Architect’s / engineer’s certificate not attached | Submit Form 1 + Form 2 + Form 3 together to the bank |
Validity Period of a Certificate Under RERA
| Certificate | When It Applies / Validity |
|---|---|
| Form 3 (Withdrawal) | Point-in-time; tied to the position on the date certified and to a specific withdrawal request |
| Form 1 / Form 2 (Architect / Engineer) | Point-in-time; obtained alongside each Form 3 |
| Form 5 (Annual Report) | For the financial year; filed within 6 months of FY end |
| Form 4 (Completion) | Issued once, on project completion |
There is no “shelf life” like a net-worth certificate — the certificate reflects the project’s position on a date, so the bank will expect a fresh Form 3 for each new withdrawal.
Difference Between Related Certificates
| Certificate | Issued By | What It Certifies | Key Difference |
|---|---|---|---|
| Form 1 | Architect | Percentage of physical work completed | Physical progress vs sanctioned plan |
| Form 2 / 2A | Engineer | Cost incurred and quality of construction | Engineering cost & quality view |
| Form 3 | Chartered Accountant | Project cost, % completion, withdrawable amount | Financial certification for each withdrawal |
| Form 4 | Architect | Completion of the project | One-time, on completion |
| Form 5 | CA (Statutory Auditor) | Annual usage of project funds | Yearly audit, not per withdrawal |
| Net Worth Certificate | CA | Assets minus liabilities of a person/entity | Personal/entity wealth, not project funds |
| Turnover Certificate | CA | Gross revenue/turnover of a business | Revenue view, unrelated to project escrow |
Professional Responsibilities of the Chartered Accountant
Under the Chartered Accountants Act, 1949, ICAI’s Code of Ethics, and ICAI’s technical guidance on RERA, a CA issuing Form 3 / Form 5 must:
- Independently verify project cost, collections and withdrawals — not rely only on the promoter’s word
- Reconcile figures with the engineer’s (Form 2) and architect’s (Form 1) certificates
- Limit the certified withdrawable amount strictly to the percentage of completion
- Disclose the basis and limitations of the certificate
- Decline to certify where records are inconsistent or funds appear diverted
- Maintain working papers and supporting documents for the prescribed period
- Issue every certificate with a valid UDIN, membership number and FRN
- Avoid any conflict of interest and apply professional scepticism throughout
Certifying figures that the CA knows to be wrong — even under promoter pressure — can lead to ICAI disciplinary action, removal from the register, and civil/criminal liability. Integrity is not negotiable.
Penalty for Misrepresentation
| Party | Default | Consequence (RERA, 2016) |
|---|---|---|
| Promoter | Non-registration of the project (Section 3) | Penalty up to 10% of estimated project cost (Section 59); continued default — imprisonment up to 3 years and/or further fine up to 10% |
| Promoter | False information / breach of Section 4 (incl. the 70% separate-account rule) | Penalty up to 5% of estimated project cost (Section 60) |
| Promoter | Contravention of any other provision | Penalty up to 5% of estimated project cost (Section 61) |
| Promoter | Failure to comply with the Authority’s orders | Daily penalty, cumulatively up to 5% of estimated project cost (Section 63) |
| Chartered Accountant | Certifying false/unverified figures | ICAI disciplinary action (suspension/removal); professional and legal liability |
Chapter VIII of RERA (Sections 59–70) deals with offences, penalties and adjudication. Penalties are computed on the estimated project cost as determined by the Authority.
Frequently Asked Questions (40+ FAQs)
1. What is a certificate issued under RERA?
It is a family of certificates that keep project funds disciplined. The CA issues Form 3 (withdrawal certificate) and Form 5 (annual report on accounts); the architect issues Form 1 and Form 4; the engineer issues Form 2.
2. Who can issue the RERA CA certificate (Form 3 and Form 5)?
Only a Chartered Accountant in practice with a valid ICAI Certificate of Practice. Form 5 is issued by the CA who is the statutory auditor of the promoter. Cost Accountants and Company Secretaries cannot issue these.
3. What is the 70% rule under RERA?
Under Section 4(2)(l)(D), 70% of the money realised from allottees must go into a separate account in a scheduled bank, to cover construction and land cost, and can be withdrawn only in proportion to the percentage of completion.
4. What is the difference between Form 3 and Form 5?
Form 3 is obtained each time the promoter withdraws from the separate account; it certifies cost, completion and the withdrawable amount. Form 5 is the annual report on the statement of accounts, certified by the statutory auditor within 6 months of the financial year end.
5. Is the RERA CA certificate mandatory?
Yes. Banks release money from the separate account only against Form 3 (with Form 1 and Form 2). Form 5 is a mandatory annual compliance under the third proviso to Section 4(2)(l)(D).
6. How often is Form 3 required?
At registration and each time the promoter wishes to withdraw from the separate account. In practice it is often taken periodically (e.g., quarterly) with the project’s progress updates.
7. By when must Form 5 be filed?
Within 6 months after the end of every financial year, as required by the third proviso to Section 4(2)(l)(D).
8. Are the form numbers the same in every state?
The requirement is central (RERA, 2016), but each state notifies its own rules and form numbers. MahaRERA uses Form 3 and Form 5; some states number or format them differently. Use your own state’s format.
9. Can a Cost Accountant or Company Secretary issue Form 3?
No. Form 3 and Form 5 are reserved for a Chartered Accountant in practice. A CS or CMA may assist with other compliances but cannot issue these certificates.
10. How much money can be withdrawn from the separate account?
Only an amount in proportion to the percentage of completion of the project, less amounts already withdrawn. The CA certifies this withdrawable figure in Form 3.
11. How is the percentage of completion calculated?
Generally as the cost incurred on the project divided by the total estimated cost, reconciled with the architect’s and engineer’s certified physical progress.
12. Does Form 3 need both the CA’s and the promoter’s signature?
Yes. Many states (including MahaRERA) require Form 3 to be signed by both the Chartered Accountant and the promoter.
13. Is a UDIN mandatory on RERA certificates?
Yes. ICAI mandates a UDIN on certificates issued by Chartered Accountants, including Form 3 and Form 5. It can be verified on the ICAI UDIN portal.
14. What if cost figures in Form 2 and Form 3 do not match?
A mismatch is a common reason for delay or rejection. The engineer’s (Form 2) and CA’s (Form 3) figures, and the RERA-declared cost, should be reconciled before submission.
15. Can a CA refuse to issue Form 3?
Yes. If records are inconsistent, figures do not reconcile, or funds appear diverted, the CA can and should decline to certify. Professional ethics override client pressure.
16. Does a brand-new project with no bookings need Form 3?
Not for withdrawal — until money is collected from allottees there is no withdrawal from the separate account. Form 3 becomes relevant once collections begin.
17. Can GST collected from buyers be kept outside the separate account?
Several states (per RERA circulars) allow indirect taxes such as GST to be kept in a separate tax account and dealt with under tax law, rather than the project separate account. Check your state’s circular.
18. Is land cost included in the project cost for the 70% rule?
Yes. The separate account covers both construction cost and land cost, and the withdrawable amount is computed against the total estimated project cost.
19. Who issues Form 5 — any CA or the statutory auditor?
Form 5 (annual report on the statement of accounts) is issued by the Chartered Accountant who is the statutory auditor of the promoter’s enterprise.
20. What does Form 5 certify?
That the amounts collected for the project were used only for that project, and that withdrawals from the separate account were in proportion to the percentage of completion.
21. Are Form 1, 2 and 3 uploaded to the RERA website every quarter?
They are primarily submitted to the bank for fund release. Practices vary by state; some require quarterly updation of progress, while Form 5 is specifically uploaded annually.
22. What is the penalty for breaching the 70% rule?
Breach of Section 4 (including the separate-account rule) can attract a penalty up to 5% of the estimated project cost under Section 60, plus possible account freezing and other action.
23. What is the penalty for not registering the project?
Under Section 59, non-registration can attract a penalty up to 10% of the estimated project cost, and continued default can lead to imprisonment up to 3 years and/or further fine.
24. Can withdrawn funds be used for another project?
No. Funds in the separate account must be used only for the specific project. Diversion to another project or to corporate overheads is a serious violation.
25. Does a JDA landowner’s share affect the certificate?
Yes. In joint development, the 70% rule applies irrespective of whether a unit belongs to the landowner or the developer, so the CA must factor the JDA structure into the certificate.
26. How long does it take to get Form 3?
If books, bank statements and the engineer’s/architect’s certificates are ready, a CA can usually issue Form 3 within a few working days. Incomplete or unreconciled records take longer.
27. Is a separate account needed for every project?
Yes. Each registered project must have its own project-designated separate bank account; funds cannot be pooled across projects.
28. Can an NRI promoter obtain RERA certificates?
Yes. An NRI or foreign-funded promoter of an Indian project obtains Form 3 / Form 5 from an Indian CA like any other promoter, while also observing FEMA/FDI norms on the investment side.
29. Does the CA certify market value of the project?
No. The CA certifies cost-based figures — estimated cost, cost incurred, completion percentage and withdrawable amount — not the market value of the project.
30. What happens if Form 5 is filed late?
Late filing is a compliance default that can attract action by the RERA authority under the penalty provisions and may affect the project’s standing and future approvals.
31. Is project finance loan repayment allowed from the separate account?
Only to the extent it relates to that project’s land/construction cost and within the proportionate withdrawal limit; using project funds for unrelated loans is not permitted.
32. Can the estimated project cost be revised?
Yes, with proper justification (e.g., extra items certified by the engineer). A revised, well-documented estimate flows into the next Form 3.
33. Are Form 3 and Form 5 needed for commercial projects too?
Yes. RERA covers commercial as well as residential projects that require registration, so the same certification mechanism applies.
34. Does a small project below the registration threshold need these certificates?
Projects below the prescribed area/unit threshold may not require RERA registration, in which case the separate-account certification does not apply. Check the threshold under your state rules.
35. Can one CA issue both Form 3 and Form 5 for the same project?
Form 3 can be issued by a CA in practice; Form 5 must be issued by the statutory auditor. Where the same firm is the statutory auditor, it may handle both, subject to independence and ethics requirements.
36. What records must the CA retain?
Working papers, cost computations, bank statements, the allottee ledger, the engineer’s/architect’s certificates and the promoter’s representation — retained as per ICAI requirements.
37. Does ICAI provide guidance on RERA certification?
Yes. ICAI has issued technical/implementation guidance and conducted RERA programmes for members on Form 3 and Form 5 certification, in addition to its Code of Ethics.
38. Can the bank release more than the certified amount?
No. The bank should release only up to the net withdrawable amount certified in Form 3; releasing more would breach the proportionate-withdrawal rule.
39. Is RERA certification the same as a tax audit?
No. A tax audit under Section 44AB of the Income Tax Act is a separate exercise. RERA Form 3/Form 5 focus specifically on project-fund discipline, though tax records support the figures.
40. How can a buyer check whether a project is RERA-compliant?
A buyer can check the project’s registration and disclosures on the state RERA portal, where the registration number, project details and certain filings (including Form 5) are published.
41. What is the role of the engineer’s quality certificate (Form 2A)?
Form 2A is the engineer’s certification on the quality of materials and workmanship, complementing the cost certification in Form 2.
42. Can a certificate under RERA be issued digitally?
Where the state RERA portal and the bank accept digitally signed documents, a CA may issue digitally signed certificates with a UDIN. Otherwise a signed, sealed physical copy is used. Confirm the accepted mode with the bank/authority.
People Also Ask
What is Form 3 in RERA?
Form 3 is the Chartered Accountant’s certificate that lets a promoter withdraw money from the project’s separate bank account, certifying project cost, percentage of completion and the withdrawable amount.
What is Form 5 in RERA?
Form 5 is the annual report on the statement of accounts, certified by the promoter’s statutory auditor within six months of the financial year end.
What is the 70-30 rule in RERA?
70% of money realised from allottees must be kept in a separate account for land and construction cost; the remaining 30% can be used more freely. Withdrawals from the 70% are tied to completion.
Is Form 3 mandatory for withdrawal?
Yes. Banks release funds from the separate account only against Form 3, submitted with the architect’s Form 1 and engineer’s Form 2.
Who signs Form 3?
Both the Chartered Accountant and the promoter sign Form 3 in most states, including Maharashtra.
Which section of RERA deals with the separate account?
Section 4(2)(l)(D) of the Real Estate (Regulation and Development) Act, 2016.
Can a company secretary issue RERA Form 3?
No. Form 3 and Form 5 are reserved for a Chartered Accountant in practice.
What is the penalty for misuse of RERA escrow funds?
Misuse can be treated as a breach of Section 4 and attract a penalty up to 5% of the estimated project cost under Section 60, along with possible freezing of the account.
How is percentage of completion certified?
The CA computes cost incurred against total estimated cost and reconciles it with the architect’s and engineer’s certified physical progress.
Is land cost part of the project cost in RERA?
Yes. The separate account covers both land cost and construction cost.
When is Form 5 due?
Within six months after the end of each financial year.
Do form numbers differ by state?
Yes. The central requirement is the same, but each state notifies its own form numbers and formats.
Can GST be kept outside the separate account?
Several states allow GST to be kept in a separate tax account, per RERA circulars; confirm your state’s position.
Does a new project without bookings need Form 3?
Not for withdrawal, since no allottee money has been collected yet.
What is Form 4 in RERA?
Form 4 is the architect’s certificate issued on completion of the project.
Can withdrawn money be used for another project?
No. Project funds must be used only for that project.
Is RERA Form 3 the same as a net worth certificate?
No. Form 3 certifies project funds and completion; a net worth certificate certifies a person’s or entity’s assets minus liabilities.
What documents does a CA need for Form 3?
RERA registration, sanctioned plan, cost estimates, cost-incurred ledgers, separate-account statements, the allottee ledger, and the engineer’s and architect’s certificates.
Is UDIN required on RERA certificates?
Yes, UDIN is mandatory on Form 3 and Form 5.
What is the role of the statutory auditor in RERA?
The statutory auditor issues Form 5, certifying annual usage of project funds.
Can a bank release more than the certified amount?
No. The bank should release only up to the certified net withdrawable amount.
Are commercial projects covered by RERA certification?
Yes, registered commercial projects follow the same certification mechanism.
Who needs a certificate under RERA?
Primarily promoters and developers; bankers, lenders, allottees and investors rely on it.
What is the penalty for non-registration under RERA?
Up to 10% of the estimated project cost under Section 59, with possible imprisonment for continued default.
Does RERA apply to joint development projects?
Yes, and the 70% rule applies regardless of whether units belong to the landowner or developer.
How long is Form 3 valid?
It reflects the project’s position on a date, so a fresh Form 3 is needed for each withdrawal.
Can a CA refuse to certify RERA forms?
Yes, if records are inconsistent or funds appear diverted.
What is Chapter VIII of RERA?
Sections 59 to 70, dealing with offences, penalties and adjudication.
Is a tax audit the same as RERA certification?
No, they are separate exercises, though tax records support RERA figures.
Where can I verify a RERA project?
On your state RERA authority’s official portal using the project’s registration number.
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External Authority References
Conclusion
A certificate issued under RERA — chiefly the CA’s Form 3 and Form 5 — is the financial backbone of buyer protection in real estate. It ties every rupee withdrawn from the project’s separate account to real, certified progress, and confirms each year that the money was used only for that project.
For promoters, getting this right means smooth fund release, clean RERA compliance, and avoidance of penalties under Sections 59–63. The key is accurate records, reconciled architect/engineer/CA figures, and certification by a qualified Chartered Accountant with a valid UDIN.
Disclaimer: The issuance of any certificate under RERA (including Form 3 and Form 5) depends entirely upon verification of the records provided and the professional judgement of the Chartered Accountant. Form numbers, formats and thresholds vary by state and may change; readers must follow their own state RERA authority’s prescribed format and the latest provisions. This article is for educational purposes only and does not constitute legal, financial or professional advice. MicroAdvisor and the issuing CA do not guarantee acceptance of any certificate by any bank, authority or other party.
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