Two provisions in Chapter 2 answer questions buyers are usually told are none of their business. One says the plans should already be published. The other says how long a permission stays alive, and what stops the clock.

Key takeaways

  • Regulation 2.6.4 requires the Authority to publish all plans relating to a sanctioned permission on its website, and to keep them there until one month after the last occupancy certificate.
  • A commencement certificate is valid for four years in aggregate, but must be renewed every year from the date of issue.
  • Renewal runs for three consecutive one year terms, after which fresh proposals are required. It may not be renewed beyond four years in any case.
  • If work commences within the valid period, no renewal is needed and the permission lasts until the work is complete.
  • Commencement means work up to plinth level, or the upper level of the lower basement or stilt where there is no plinth.
  • Ten categories of work need no permission at all, including safety grills, solar panels up to 1.8 m above the terrace, and internal partitions in commercial buildings.

The plans should already be online

Chapter 2, Regulation 2.6.4, UDCPR as updated 30 January 2025 is one sentence and it is the most useful thing in this article.

After sanction of the development permission, the Authority shall make available all plans relating to such permission on its website, if available. Those documents shall be kept on the website until one month from the date of issuance of the last occupation certificate.

Tip

That obligation runs for the entire life of a project's construction and a month beyond it, which is precisely the window in which a buyer needs it.

It is worth pairing with Regulation 2.8.3, the display board at the site gate, which carries the order number and date of the permission. The board gives you the reference; the website obligation gives you the reason you are entitled to see the documents behind it.

The regulation does contain a qualifier, "if available", and practice varies between authorities. But a request for a sanctioned plan is not an unusual favour to ask for. It is a document the code contemplates being published.

A permission has a life, and a clock

Chapter 2, Regulation 2.7.1, UDCPR as updated 30 January 2025* is where projects quietly go wrong, and it works on two timers at once.

How long a commencement certificate lasts

Banded by what has happened

  1. Aggregate validityFour years, and in no case renewed beyond four years from the date of the commencement certificate or development permission
  2. Annual renewalMust be renewed every year from the date of issue, applied for before the expiry of one year where the work has not commenced. Renewal for three consecutive terms of one year.
  3. After the three renewalsProposals must be submitted afresh to obtain development permission again
  4. Late renewalThe Authority may condone the delay on payment of one third of the Regulation 2.2.12 fee per year, but still not beyond the four year outer limit
  5. Work commenced in timeNo renewal is necessary, and the permission remains valid until the work is completed

Source: Chapter 2, Regulation 2.7.1, UDCPR as updated 30 January 2025

The fee that band refers back to is set by Chapter 2, Regulation 2.2.12, Building / Layout Permission Scrutiny Fee#, and it is worth knowing what a third of it is a third of. The scrutiny fee is banded by authority: Rs 2,000 per 0.4 hectare for a plotted layout and Rs 5 per sq m of built-up area in Pune, Pimpri-Chinchwad, Nagpur, Nashik, the Municipal Corporations in MMR and Metropolitan Authority areas; Rs 1,500 and Rs 4 in the remaining Municipal Corporations, A Class Municipal Councils and the Mumbai Metropolitan Regional Plan area; and Rs 500 and Rs 2 in B and C Class Municipal Councils, Nagar Panchayats and Regional Plan areas. Proposals implemented by Government departments or by public authorities of the State or Central Government pay nothing.

Three notes on that regulation decide whether you pay twice. No scrutiny fee is levied when a proposal comes back after you have complied with objections the authority itself raised. A revised permission does attract the fee. But where a revision proposes additional work without disturbing what was already approved, the fee is charged only on the additional work. The regulation carries a clarification marker in the UDCPR contents, issued under Order No.CR.236/18 dated 23 December 2021, and it opens by making the fee subject to Government orders, so the figures above are the consolidated position rather than a permanent one.

The last band is the one that matters most, and it turns on a definition.

Commencement, for a building work including additions and alterations, means work up to plinth level, or where there is no plinth, up to the upper level of the lower basement or stilt as the case may be. For bridges and overhead tanks it means the foundation and work up to the base floor or underground portion.

Warning

Read those two things together and the practical position is clear. A project that reaches plinth level inside its valid permission has stopped the four year clock, and its permission runs until the work is finished. A project that has not reached plinth is living on annual renewals with a hard outer limit.

That is why the plinth checking requirement in Regulation 2.8.4 is more than a formality. The intimation given after plinth level, certified by the architect or engineer, is the moment a permission changes character.

For a buyer looking at a long delayed project, the question worth asking is not only when construction will restart. It is whether the original permission is still alive, or whether fresh development permission will have to be obtained, because the second answer means the scheme may be re-approved under whatever the regulations say by then rather than what they said at launch.

What needs no permission at all

Chapter 2, Regulation 2.1.2, UDCPR as updated 30 January 2025*** lists ten categories where no permission is necessary. Several are useful to know as an owner rather than as a developer.

  • Works carried out in compliance with an order or direction of any Authority under any law in force, and works by an Authority exercising its own powers.
  • Excavation, including of wells, in the ordinary course of agricultural operations, and construction of a road giving access to land solely for agricultural purpose.
  • Normal use of land used temporarily for other purposes such as marriage pandals or festive occasions on private land.
  • Provision of safety grills to a window or ventilator.
  • A distribution or receiving substation of the electricity supply company.
  • Installation of solar panels with the base of the panel at a height up to 1.8 m from the terrace, ensuring structural stability certified by a licensed structural engineer.
  • Internal lightweight partitions or cabins in a commercial building, with a certificate of structural stability from a licensed structural engineer.
  • Temporary structures for godowns or storage of construction materials within the site.

Two of those carry conditions rather than being free-standing permissions. The solar panel exemption is tied to the same 1.8 m figure that Regulation 6.11 uses to keep solar panels out of the height computation, and both the panel and the internal partition exemptions require a structural stability certificate from a licensed structural engineer.

Chapter 2, Regulation 2.6.3, Approval of building permission on Risk Based Classification adds a route that changes how much scrutiny some proposals receive: notwithstanding anything else in UDCPR, approval for low or moderate risk categories of construction is governed by the separate procedure in the appendix. It is worth knowing that a project's approval path may have been the lighter one.

What to check

  1. Look for the sanctioned plans on the Planning Authority's website before asking the developer, because Regulation 2.6.4 contemplates them being there.
  2. Take the permission's order number and date from the display board at the site.
  3. Ask whether the project has reached plinth level, since that is what stops the four year clock.
  4. On a stalled project, ask whether the permission was renewed and how many of the three annual terms have been used.
  5. Ask which approval route was used, because the risk based classification in Regulation 2.6.3 follows a different procedure.

Where the filings come in

The RERA register and the Planning Authority hold different halves of this. The Authority holds the permission and the plans. The register holds the project's own account of how the work has gone.

That account is the useful one for the timing question: original and current completion dates, every extension with the reason the promoter gave, progress against the eleven activity checklist building by building, and any complaints or litigation with case numbers. It is free to read at reragenie.com.

ReraGenie's buyer report, Rs 499, reads one project's full filing and the documents behind it, compares the slip between original and current completion dates against the median for the same pincode, sets the promoter's record against the rest of the register, and lists what the filings do not contain. It includes a project watch for 90 days.

For what each certificate at the other end of the process actually proves, see completion, occupancy and part OC.

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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