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Compliance

Form 5 and the project account: what the annual RERA audit really tests

Adv. Gauri GabureAdv. Gauri Gabure24 Jun 2026 6 min read

The rule is easy to recite: seventy per cent of the amounts realised from allottees goes into a separate project account and is used only for that project's construction and land cost. The annual audit is where the recitation meets the ledger.

What the auditor is certifying

Form 5 is a chartered accountant's certification that withdrawals from the project account are in proportion to the percentage of completion — that money taken out matches construction actually delivered, certified by the engineer and architect alongside.

Where the breach usually happens

  • Funding an early-stage project from a later-stage one because the cash is sitting there.
  • Treating overheads and marketing as project cost without a defensible allocation basis.
  • Withdrawing against optimistic completion certificates that later have to be revised down.
The account is per project, not per promoter. Fungibility is exactly what the provision was written to prevent.

Reconcile quarterly rather than annually. An error found in March is a correction; the same error found in an audit is a disclosure.

This article is general information, not legal advice. For guidance on your specific situation, book a consultation.
Adv. Gauri Gabure

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Adv. Gauri Gabure

Associate — Compliance

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