RERA Certification & Annual Audit of Project Accounts

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Practice Overview & Verification

RERA Certification & Annual Audit of Project Accounts — Statutory Scope

Chartered Accountancy advisory and audit services in Raipur, Chhattisgarh & Kalahandi, Odisha. Direct partner supervision ensuring full compliance with ICAI standards and applicable statutes.

A promoter of a registered real estate project must deposit seventy per cent of the amounts realised from allottees into a separate account for that project, and may draw on it only for the cost of construction and the cost of land. Money cannot be moved out of that account on the promoter's own authority. Each withdrawal requires certification, and the project's accounts must be audited every year by a Chartered Accountant in practice.

These are not discretionary compliances. They are the mechanism by which the Act protects homebuyers, and the certification is what the bank relies on to release funds. A promoter without current certification cannot draw on its own project receipts.

We provide RERA certification and annual audit of project accounts for promoters and developers of projects in Raipur, Naya Raipur and across Chhattisgarh.

What the Act requires

The separate account. Seventy per cent of the amounts realised from allottees for a real estate project must be deposited in a separate account maintained in a scheduled bank, and used only to cover the cost of construction and the cost of land for that project. Funds of one project cannot be applied to another.

Certification for each withdrawal. Amounts may be withdrawn from that account only after certification by three professionals — an engineer, an architect, and a Chartered Accountant in practice — that the withdrawal is in proportion to the percentage of completion of the project. All three certificates are required; the Chartered Accountant's is one of them and cannot be substituted.

Annual audit of project accounts. The promoter must get its accounts audited within six months after the end of every financial year by a Chartered Accountant in practice, and produce a statement of accounts duly certified and signed. The audit must verify two things specifically: that the amounts collected for a particular project have been used for that project, and that withdrawals have been in compliance with the proportion to the percentage of completion.

Both obligations arise from Section 4(2)(l)(D) of the Real Estate (Regulation and Development) Act, 2016 — the second proviso for withdrawals and the third proviso for the annual audit.

CG RERA Statutory Certification & Annual Audit Compliance Matrix

Statutory Compliance	Governing Section / Form	Certifying Professional	Statutory Due Date / Trigger	Core Audit & Verification Scope
Quarterly Fund Withdrawal Certificate	Section 4(2)(l)(D) / Form 3	Chartered Accountant in Practice (Independent)	Prior to each bank withdrawal (or quarterly)	Certifies % of construction completion vs land & civil cost incurred
Architect Progress Certificate	Section 4(2)(l)(D) / Form 1	Empaneled Architect (Council of Architecture)	Quarterly / Prior to fund draw	Certifies physical percentage of work completed for each building block
Engineer Completion Certificate	Section 4(2)(l)(D) / Form 2	Site Structural / Civil Engineer	Quarterly / Prior to fund draw	Certifies actual cost incurred on construction materials & labor
Annual RERA Project Audit	Section 4(2)(l)(D) 3rd Proviso / Form 5	Promoter's Statutory Auditor (CA in Practice)	Within 6 months of FY end (by 30th September)	Audits 70% designated escrow account, verifies zero fund diversion
Quarterly Progress Report (QPR)	Section 11(1)(b) / CG RERA Web Portal	Promoter & Authorized CA/Architect	Within 15 days of each calendar quarter end	Online update of booking count, approvals obtained, photos & completion status

Statutory Compliance: Quarterly Fund Withdrawal Certificate

Governing Section / Form: Section 4(2)(l)(D) / Form 3

Certifying Professional: Chartered Accountant in Practice (Independent)

Statutory Due Date / Trigger: Prior to each bank withdrawal (or quarterly)

Core Audit & Verification Scope: Certifies % of construction completion vs land & civil cost incurred

Statutory Compliance: Architect Progress Certificate

Governing Section / Form: Section 4(2)(l)(D) / Form 1

Certifying Professional: Empaneled Architect (Council of Architecture)

Statutory Due Date / Trigger: Quarterly / Prior to fund draw

Core Audit & Verification Scope: Certifies physical percentage of work completed for each building block

Statutory Compliance: Engineer Completion Certificate

Governing Section / Form: Section 4(2)(l)(D) / Form 2

Certifying Professional: Site Structural / Civil Engineer

Statutory Due Date / Trigger: Quarterly / Prior to fund draw

Core Audit & Verification Scope: Certifies actual cost incurred on construction materials & labor

Statutory Compliance: Annual RERA Project Audit

Governing Section / Form: Section 4(2)(l)(D) 3rd Proviso / Form 5

Certifying Professional: Promoter's Statutory Auditor (CA in Practice)

Statutory Due Date / Trigger: Within 6 months of FY end (**by 30th September**)

Core Audit & Verification Scope: Audits 70% designated escrow account, verifies zero fund diversion

Statutory Compliance: Quarterly Progress Report (QPR)

Governing Section / Form: Section 11(1)(b) / CG RERA Web Portal

Certifying Professional: Promoter & Authorized CA/Architect

Statutory Due Date / Trigger: Within 15 days of each calendar quarter end

Core Audit & Verification Scope: Online update of booking count, approvals obtained, photos & completion status

⚠️ Statutory Penalty & Risk Advisory

Only a Chartered Accountant can issue these

The Act reserves both the withdrawal certificate and the annual report on the statement of accounts to a Chartered Accountant in practice. A Cost Accountant or a Company Secretary cannot issue either. This is not a matter of preference or convention — it is what the statute provides, which is why a promoter has no alternative but to engage a Chartered Accountant for this work.

There is a further point that promoters frequently do not know until it causes a problem. The Chartered Accountant who certifies project progress for the purpose of withdrawal is generally required to be a different person from the Chartered Accountant who acts as the promoter's annual auditor and issues the annual report on the statement of accounts. The two roles are deliberately separated, so that the annual audit is a genuine check on the withdrawal certificates rather than a review of one's own work.

The practical consequence is that a promoter needs two Chartered Accountants, not one — and where a promoter's existing auditor has been issuing both, the position should be corrected. We are able to take on either role, and we establish at the outset which one is appropriate given who else is engaged.

⚙️ Step-by-Step Procedure & Workflow

The certificates in practice

The withdrawal certificate. Required at registration and again each time the promoter proposes to withdraw from the separate account. In practice it is commonly obtained periodically alongside the project's progress reporting, often quarterly, because construction draws are continuous rather than occasional. It is submitted to the bank, together with the architect's and engineer's certificates, as the basis on which funds are released.

Issuing it properly requires the estimated cost of the project, the cost incurred to date, an assessment of the percentage of completion, and a reconciliation of amounts received from allottees against amounts deposited into and withdrawn from the separate account. Where the professional certificates from the architect and engineer do not agree with each other or with the financial position, that has to be resolved before the certificate is issued rather than noted afterwards.

The annual report on the statement of accounts. Due within six months of the financial year end, issued by the promoter's statutory auditor, and covering the whole year's movement on the separate account. It is filed with the authority and is a public document — allottees can read it. Where it discloses that a withdrawal was not in proportion to completion, or that project funds were applied elsewhere, that disclosure is on the record permanently.

Because it is a public document, and because it reports on certificates issued during the year by others, this is not a routine certification exercise. It is an audit, and the work has to be capable of supporting the opinion.

Form numbering. The obligations are central, arising from the Act itself, but the certificate formats are notified by each state authority and the form numbers differ between states. Certificates for projects in Chhattisgarh follow the formats notified by the Chhattisgarh authority. Where a promoter operates in more than one state, the formats will not be the same in each.

📋 Document Checklist & Verification

What we need from the promoter

✓The RERA registration certificate for the project, and the declared project details
✓The estimated cost of the project — land cost and cost of construction, with any revision
✓Bank statements for the separate account, and for the collection account where a separate one is used
✓Details of amounts realised from allottees, allottee-wise
✓Ledgers of project expenditure, with supporting bills and payment records
✓The architect's and engineer's certificates for the period
✓Copies of certificates previously issued, for the annual audit
✓Details of any borrowing against the project, and its application

⚠️ Statutory Penalty & Risk Advisory

Why this matters to a promoter beyond compliance

Funds do not move without it. The bank releases money from the separate account against the certificates. A promoter without current certification cannot access its own project receipts, which stops construction and, in turn, delays the completion on which the next set of withdrawals depends.

The account is examined annually and publicly. The annual report is filed and available. Discrepancies do not stay private.

Contravention carries penalty. Breach of the separate-account requirement is a contravention of Section 4, which attracts penalty under the Act. More practically, it also attracts the attention of the authority to the project as a whole.

Allottees have remedies. Where project funds have been diverted, allottees can complain to the authority, and the promoter's own records become the evidence.

Projects in Raipur and Naya Raipur

Chhattisgarh has an active development pipeline — residential and plotted development around Raipur, and continuing development in Naya Raipur — and promoters here face the same certification requirements as anywhere else in India, applied through the state authority's notified formats.

Two situations recur locally. The first is the promoter developing a plotted or small residential project for the first time, who registers the project without appreciating that seventy per cent of receipts must go into a designated account from which withdrawals require three professional certificates. The second is the established builder running several projects through common accounts, for whom the separation of project funds is the real work. Both are better addressed at registration than at the first withdrawal.

Scope of our work

We advise on the operation of the designated account and on the records needed to support certification; assess the percentage of completion in conjunction with the architect's and engineer's certificates; issue the Chartered Accountant's certificate for withdrawal in the format notified by the authority; conduct the annual audit of project accounts and issue the annual report on the statement of accounts within the six-month period; reconcile amounts realised from allottees against deposits into and withdrawals from the designated account; and advise promoters running multiple projects on separating project accounting so that each project can be certified independently.

Where we act as the annual auditor, we do not also issue withdrawal certificates for the same promoter, and vice versa — for the reason set out above.

📍 Pandri, Raipur Practice Headquarters

Consult CA in Raipur for RERA Certification & Annual Audit of Project Accounts

Visit our Head Office at GF-28, Shyam Plaza, Pandri, Raipur or connect directly with our Chartered Accountant partners for end-to-end advisory and statutory compliance.

🏛️ CA in Raipur Hub →📞 +91 86978 14116

Who can issue the RERA certificate for withdrawal from the designated account?

A Chartered Accountant in practice. The Act requires certification by an engineer, an architect and a Chartered Accountant that the withdrawal is in proportion to the percentage of completion, and all three are needed. A Cost Accountant or Company Secretary cannot issue the Chartered Accountant's certificate — it is reserved by statute.

Can my statutory auditor issue both the withdrawal certificates and the annual report?

Generally no, and this catches promoters out. The Chartered Accountant certifying project progress for withdrawals is required to be a different person from the one acting as the promoter's annual auditor and issuing the annual report on the statement of accounts. The separation exists so that the annual audit is an independent check on the withdrawal certificates rather than a review of the same firm's own work. A promoter therefore needs two Chartered Accountants for RERA purposes.

When is the annual audit of project accounts due?

Within six months after the end of every financial year. The report is filed with the authority and is a public document, so allottees are able to read it. It must specifically verify that amounts collected for the project were used for that project, and that withdrawals were in proportion to the percentage of completion.

How often do I need a withdrawal certificate?

At registration, and thereafter each time you propose to withdraw from the designated account. Because construction spending is continuous, promoters commonly obtain certification periodically — frequently quarterly, alongside progress reporting — rather than on each individual withdrawal. The bank releases funds against the certificates, so in practice the frequency is driven by the drawdown schedule.

What is the seventy per cent rule?

Seventy per cent of the amounts realised from allottees for a project must be deposited in a separate account maintained in a scheduled bank, and applied only to the cost of construction and the cost of land for that project. The remaining thirty per cent is not subject to that restriction. The purpose is to ensure that money collected for one project is actually spent on it and not diverted to another.

Can I use funds from one project for another?

No. The designated account is project-specific, and the certification and annual audit both test precisely this — whether amounts collected for a particular project were used for that project. Cross-application of project funds is a contravention of Section 4 and is the issue the annual report is most likely to expose.

I am developing a plotted scheme in Raipur. Do these requirements apply to me?

If the project requires registration with the authority, then yes — the designated account, the certification for withdrawal and the annual audit all apply to plotted development as they do to construction projects. First-time promoters frequently register a project without appreciating this, and then find that receipts already banked are not accessible in the way they expected. It is worth setting the account structure up correctly at registration.

I run several projects through common books of account. Is that a problem?

It will be when a certificate is required. Each registered project needs its own designated account and its own certifiable financial position, so common accounting has to be separated before a Chartered Accountant can certify a withdrawal or report on the year. This is the most common practical difficulty we see with established builders, and it is far easier to address at the outset than retrospectively.

Do the form numbers differ between states?

Yes. The obligations come from the central Act, but each state authority notifies its own rules and certificate formats, and the numbering is not uniform. Certificates for a project in Chhattisgarh follow the state authority's notified formats. A promoter operating in more than one state will be issuing certificates in different formats for each.

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