The June 2024 bank account order is the most operationally consequential circular MahaRERA has issued, and the least read by the people it governs. It converted the 70 percent rule from an accounting obligation into banking architecture: three named accounts, fixed transfer logic, and a hard bar on lender encumbrance. Promoters who wire their treasury to it run clean by default; promoters who bolt it on discover the gaps at audit, or in a scrutiny letter. Here is the regime as an operations manual.
Key takeaways
- Order MahaRERA/Secy/129/2024 (27 June 2024, effective 1 July 2024): Collection Account receives everything, Separate Account holds the 70 percent for land and construction, Transaction Account takes up to 30 percent.
- Parking, amenity and similar charges are inside the Collection Account's net; taxes and statutory duties are out.
- Accounts must be unencumbered and beyond third-party control, which reshapes how project finance can be secured.
- Multi-promoter revenue-share structures route through a Master Account before each promoter's 70/30 split.
The architecture, as your bank sees it
Collection Account. The single intake: every rupee from allottees, instalments, parking, amenities, club charges, lands here first. Taxes and statutory duties stay outside. The account's completeness is the order's first innovation: the historic leak of "other charges" collected in side accounts is closed by definition.
Separate Account. Receives 70 percent of Collection Account realisations, spendable solely on the project's land and construction cost, drawable only against the Form 1/2/3 certificate cycle, closable only at completion after dues. This is the statutory fence of Section 4(2)(l)(D), now with its own IFSC.
Transaction Account. Up to 30 percent, the promoter's lawful liquidity for overheads, marketing, finance costs and margin. Ordinary business account in every respect except its named place in the structure.
Master Account, where applicable. Revenue-share projects with multiple promoters collect centrally, split to each promoter's Collection Account by share, then bifurcate 70/30. The structure that previously lived in inter-company memos now lives in bank mandates.
And across all of them, the clause with teeth: free of encumbrance, lien, loan and third-party control, unattachable except on MahaRERA's own orders.
An analogy: from double-entry to direct debit
The old regime was double-entry bookkeeping: the split existed because your accountant recorded it. The new regime is a standing instruction: the split happens because the banking executes it. Nobody audits whether a direct debit occurred; they audit whether it was set up correctly once. That is the shift to make internally: the compliance work moved from monthly discipline to day-one design, and design errors, unlike discipline lapses, replicate every month until found.
Day-one setup, done right
- 1
Open the trio at registration
Same bank for all three simplifies transfer automation and certificate-linked release; the account details become part of the registration filing.
- 2
Write the transfer logic into the mandate
Standing 70/30 bifurcation from Collection on realisation, not month-end; the order's percentages as bank rules, not finance-team tasks.
- 3
Route every demand letter to Collection
Instalments, parking, amenities, club: one account on every invoice. Sales teams improvising payment instructions is how clean structures leak.
- 4
Restructure lender security
The encumbrance bar means facilities cannot take lien over these accounts; escrow-of-receivables structures need redesign around the Transaction Account and other collateral. Involve the lender's counsel early.
- 5
Document the multi-promoter split
Where a Master Account applies, the revenue-share percentages in the development agreement, the bank mandate and the RERA filing must be one number.
Source: MahaRERA Order No. MahaRERA/Secy/129/2024
The traps the first audits found
The legacy lien. Facilities predating July 2024 with charge over project accounts: the order's bar and the lender's security now conflict, and the resolution belongs in a renegotiation, not in hoping nobody reads the sanction letter.
The amenity side-pocket. Parking and amenity charges billed by a group entity outside the Collection Account. The order names these receipts explicitly; the practice is now a violation with a paper trail.
Percentage drift. Transfers run manually, month-end, on estimates, drifting from the realisation-linked split. Bank-automated bifurcation costs nothing and removes the drift class entirely.
The forgotten closure rule. The Separate Account closes after completion and dues, not at OC celebration. Iqbal (our illustrative Thane builder) budgeted the account's life to his OC date and met his CA's veto: post-OC dues and the Form 5 audit cycle keep the fence standing past the party.
The regime is also a lender-relations asset. A project whose banking enforces the split by mandate presents cleaner to project-finance committees than one promising the same by policy, and the public certificate trail the accounts generate is underwriting evidence. The order most promoters read as constraint prices, for disciplined operators, as credit quality.
The same pipes, read from outside
Buyers are being taught to trace this plumbing from its public shadows, and lenders and counterparties read the same filings. Your account discipline is legible in the certificate rhythm and the construction-versus-collections curve, which is one more page of the register's open book. ReraGenie's Rs 2,999 project analysis reads that book for any Maharashtra project, your own treasury's public reflection before a lender meeting, or a JV counterparty's before you share a Master Account with them.
The one-line summary
Three accounts, one intake, a 70 percent fence with three-signature gates, a 30 percent working pocket, and no lien on any of it: wire the treasury to the order on day one, align the lender documents, and the strictest circular MahaRERA has issued becomes the cheapest compliance you run.
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