A borrower's progress report is an assertion. The permission chain is a sequence of documents issued by somebody else. That difference is the whole reason to read it before money moves, and three of its conditions can stop a finished building from being handed over even when the construction is genuinely complete.
Key takeaways
- The permission chain is externally issued, which is what makes it independent evidence rather than borrower narrative.
- Four checks, in order: does the permission exist and is it current, was it obtained on true statements, is the premium paid, and did it arrive by deemed permission.
- Regulation 2.2.14 grants the Occupation Certificate in proportion to premium instalments paid. This is a handover constraint that construction progress cannot cure.
- Regulation 2.15 permits revocation for a false statement in the application, with the whole work then treated as unauthorised and no compensation paid.
- Regulation 2.6.2 deemed permission sanctions a CONFORMING proposal only. A non-conforming one becomes unauthorised development.
- Sanctioned plans are public on the Authority's website until a month after the last occupancy certificate, under Regulation 2.6.4.
- 23.4 percent of Maharashtra's published registrations have filed at least one extension, and at the 90th percentile the promised date moved by 730 days.
- Recovery on a RERA award is not a reliable exit: about 31 percent of MahaRERA recovery warrants had been executed as at July 2025.
Why the chain, and not the progress report
A construction tranche is released against progress, and progress is the one thing in a credit file that the borrower controls the reporting of.
The permission chain is different in kind. Every document in it is issued by a Planning Authority, on an application made through a licensed professional, after a check the lender did not have to perform. It behaves like a series of locks in a canal: a boat cannot skip one, and the water level in each is set by somebody other than the boat's owner. That is precisely why the chain is worth reading, and why reading it badly is worse than not reading it at all, because each certificate carries conditions that are not written on its face.
This matters more since the Reserve Bank of India (Project Finance) Directions, 2025, effective 1 October 2025, which set a general provision of 1.25 percent on under-construction Commercial Real Estate exposures, reducing to 1 percent in the operational phase, across commercial banks other than payments banks, RRBs and local area banks, NBFCs including HFCs, primary urban co-operative banks and all India financial institutions. Projects that had achieved financial closure before that date continue under the earlier norms. The regulatory distinction between "under construction" and "operational" is now a provisioning line, and the documents that move a project across it are the last two links in this chain.
The context for how much care this deserves is in the RBI Financial Stability Report, June 2026. Scheduled commercial banks' gross NPA ratio stood at 1.8 percent as at March 2026, a multi-decadal low, with CRAR at 17.7 percent.
But the same report's NBFC stress test is the number to underwrite against rather than the headline. Across 174 NBFCs, the aggregate GNPA ratio rises from 2.3 percent to 5.4 percent under the severe credit stress scenario, with CRAR falling from 22.8 percent to 20.9 percent.
A book that looks comfortable at 2.3 percent and uncomfortable at 5.4 percent is a book whose outcome is decided by which individual exposures turn, not by the average. Document-level checks are how that gets decided.
The four checks, in order
The order matters, because each check is cheap only if the one before it passed.
1. Does the permission exist, and is it current?
Chapter 2, Regulation 2.2, UDCPR as updated 30 January 2025 requires the application to be made through a registered architect, town planner or licensed engineer or supervisor, on the prescribed form, with the plans and statements required by Regulations 2.2.2 to 2.2.19. Chapter 2, Regulation 2.2.3, Ownership Title and Area* then lists the ownership documents, and two of them are worth a credit officer's attention:
- The 7/12 extract or property register card must be dated not earlier than six months before submission. An older one did not support the application.
- On a revised permission where interest has been created by a registered agreement to sell, the consent of those buyers is required, as specified under the RERA Act. A borrower who has revised a sanctioned scheme mid-project should be able to produce that consent, and its absence is a specific question rather than a general worry.
On Government or local authority leasehold land, an NOC is required not only where the scheme deviates from lease conditions but also where it proposes to use more FSI than the lease deed mentions. Leasehold plots carry their own FSI figure, and exceeding it is a separate permission from exceeding the zone's.
2. Was it obtained on true statements?
Chapter 2, Regulation 2.15, Revocation of Permission is four lines and it is the most severe provision in the chapter. The Authority may, after a hearing, revoke any development permission where there had been any false statement or misrepresentation of material fact in the application. The whole work carried out under that permission is then treated as unauthorised, and no compensation is paid.
The exposure is retrospective in effect. A structure financed in good faith, built by a competent contractor and sold to buyers sits on a permission that can be unwound because of what the application said years earlier. That makes the Regulation 2.2.3 document set a diligence item in its own right rather than a formality cleared at sanction, and it is the reason to obtain the application papers and not merely the certificate they produced.
3. Is the premium paid, and on what schedule?
This is the check that is almost always missing, and it is the one that can surprise a repayment model.
Chapter 2, Regulation 2.2.14, Premium Charges and Fire Infrastructure Charges* permits premium charges, except premium leviable under Chapter 5, to be paid in instalments at 8.5 percent per annum on the reducing balance. Two options:
| Option | Schedule | Security |
|---|---|---|
| Option 1, building below 70.0 m | 10 percent initially, then 22.5 percent at each of 12, 24, 36 and 48 months | Post-dated cheques for each instalment with interest, on a scheduled bank |
| Option 1, building 70.0 m and above | 10 percent initially, then 18 percent at each of 12, 24, 36, 48 and 60 months | Same |
| Option 2 | 20 percent at the Commencement Certificate, 80 percent at the occupation certificate | Same |
And then the condition that reaches the lender: the Occupation Certificate shall be granted in proportion to the payments made.
Worked example. A 200 unit tower below 70 m, premium of Rs 20 crore, borrower on Option 1. Construction completes at month 30.
Premium paid by month 30 is the 10 percent initial payment, plus the instalments due at months 12 and 24: 10 + 22.5 + 22.5 = 55 percent, or Rs 11 crore. The instalments at months 36 and 48 are not yet due.
On the face of Regulation 2.2.14, the occupancy entitlement at that point is proportionate to 55 percent, which on a 200 unit tower is roughly 110 units. The remaining 90 units are built, finished and not handed over.
For the lender, the consequence is not a construction delay. It is a receipts delay on a completed asset: the sale proceeds that the repayment schedule assumed would arrive on completion arrive against 55 percent of the tower, and the balance follows the premium schedule rather than the works programme. Interest continues to accrue on the full facility throughout.
The fix is available and it is a sanction condition, not a workout: Option 2 puts 80 percent of the premium at the occupation certificate, which aligns the payment with the receipts. A facility that funds the premium as a permitted end-use, or a covenant requiring Option 2, removes the exposure entirely. Neither is possible after the borrower has already elected Option 1 and lodged post-dated cheques.
Chapter 2, Regulation 2.2.13, Development Charges* is the smaller sibling and mostly runs the borrower's way: development charges are adjusted against a future permission where no development was carried out and the permission lapsed or was cancelled at the owner's request, and are not recovered at all on maintenance, internal repairs or strengthening that consumes no additional floor space.
4. Did the permission arrive by deemed permission?
Chapter 2, Regulation 2.6.2, Deemed Permission provides that if the Authority does not intimate its refusal or sanction within 60 days, the proposal is deemed sanctioned. That sounds like a clean outcome and it is a conditional one.
The deeming applies only where the proposal is strictly in conformity with these regulations and violates no draft or final Development or Regional Plan. Where it is not, development carried out under that deemed permission is deemed unauthorised development for the purposes of sections 52 to 57 of the MR and TP Act, 1966.
So "we have deemed permission" answers how the permission arrived, not whether the scheme was entitled to it. The compliance question stays open, and unauthorised development is a risk to the building rather than to the file. Where a borrower's permission arrived this way, the conformity check that the Authority did not perform has to be performed by somebody, and on a financed project that somebody is the lender's technical consultant.
What is checkable without asking the borrower
Chapter 2, Regulation 2.6.4, Display of Sanctioned Permissions on Authority's Web-Site is the provision that makes this a desk exercise rather than a request. After a development permission is sanctioned, the Authority shall make available all plans relating to it on its website, and keep them there until one month from the issuance of the last occupation certificate.
For the whole life of a project, therefore, the sanctioned plans are meant to be publicly retrievable, and the colour notation that makes them legible is fixed by regulation. Red hatched is the notation for deviations. A monitoring visit that photographs the site is doing less work than a periodic re-pull of the sanctioned set, because the second one shows what the Authority thinks has changed.
What the register adds, and where it stops
MahaRERA registration begins after the Commencement Certificate, so the register cannot show the application, the 60 day wait or the premium schedule. What it does publish, free and quarterly, is the record of promises moving.
Source: ReraGenie analysis of MahaRERA filings, captured 15 August 2026
23.4 percent of published registrations have filed at least one extension, and 7.5 percent have filed two or more. The date movement is more skewed than the extension count: across 55,451 registrations filing both an original and a proposed completion date, the median movement is zero days, and at the 90th percentile it is 730 days. Most projects do not move their date at all, and the ones that move, move by years.
That shape is what makes a portfolio-level average useless and a per-exposure check valuable. It is also why the extension text matters more than the extension count: the filing carries the promoter's own stated reason, in their words, and a reason that does not describe construction is a different signal from one that does.
Do not underwrite the RERA remedy as the recovery path.
MahaRERA issues recovery warrants against promoters, executed by the district collectorates. As at July 2025, roughly 31 percent of recovery warrant cases had been executed, with about Rs 233 crore recovered across 352 complaints and about Rs 760 crore outstanding across 1,212 cases. Mumbai suburban district alone accounted for 540 complaints worth Rs 424.79 crore, of which Rs 80.49 crore had been recovered.
An award is not a receipt. A recovery assumption built on RERA enforcement should be discounted to something close to the observed execution rate, and the security package should not depend on it.
How Kavya reads a file
Kavya Menon heads real estate credit at a Mumbai NBFC with a developer book across MMR and Pune. Her tranche memo asks four questions in the order above, and she has stopped accepting a certificate without the conditions attached to it.
The one that changed her template was the third. A borrower's tower topped out on schedule, and the handover ran in tranches nobody had modelled, because the premium was on Option 1 and the occupancy entitlement tracked the instalments. Nothing had gone wrong on site, no covenant had been breached, and the receipts arrived a year late against a facility accruing interest throughout.
Her sanction conditions now require the premium election in writing, and the facility funds the premium where Option 2 is elected. It costs the borrower nothing and removes a risk that construction monitoring cannot see.
Names and numbers in this story are illustrative.
Related reading
- How to read a sanctioned plan without being an architect
- From application to Commencement Certificate
- Development charges, premium in instalments, and revocation
- Completion, occupancy and part OC: what each proves
- What RERA filings tell a lender that the borrower's MIS cannot
Where the filings come in
The permission chain sits with the Planning Authority. The register is the independent record of what the borrower has told the regulator since.
Every project at reragenie.com is free to read and carries the filed land area, the buildings and their floors, the sanctioned and sold units where filed, the construction progress by building against the RERA activity checklist, the commencement certificates and full document list, the certifying architect, engineer and chartered accountant, the extension history with the promoter's own stated reason for each, and any complaints or litigation with case numbers.
For a monitored exposure, the ReraGenie project analysis at Rs 2,999 reads one project's full filing and the documents behind it and sets the promoter's record against the rest of the register. The area consolidated report, Rs 2,999 for the first project and Rs 1,999 per additional one, does the same across a micro-market, which is the unit a concentration limit is actually written against. A project watch, Rs 299 for 90 days, emails every change in a single filing, which is the cheapest form of covenant monitoring available on a public record.
Sources. Reserve Bank of India (Project Finance) Directions, 2025, effective 1 October 2025. Reserve Bank of India, Financial Stability Report, June 2026. MahaRERA recovery warrant execution data as reported July 2025. ReraGenie analysis of 55,456 published MahaRERA registrations, captured 15 August 2026.
Source: Unified Development Control and Promotion Regulations for Maharashtra, UDCPR as updated 30 January 2025. Sanctioned under the Maharashtra Regional and Town Planning Act, 1966.
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