Two Stages, One Afternoon

In the first half of 2026, the Gurugram bench of Haryana's real estate regulator cleared 51 projects worth roughly ₹34,000 crore, as reported by Business Today in July. That is a launch roughly every third day, in one district. In a market this busy, the marketing almost always reaches you before the paperwork does: a broker forward, a “pre launch price” WhatsApp, an EOI form with a deadline attached. Stage one takes ten minutes and eliminates the disqualified. Stage two is the part almost nobody does, and it is where the real information lives, because everything in a RERA filing is a sworn statement to a regulator with penalty powers, while everything in the brochure is marketing.

What the law actually says

The Real Estate (Regulation and Development) Act, 2016 is unambiguous. Section 3(1) reads:

Note the verbs: advertise, market, book, invite. The bar is not “collecting money.” Inviting you to buy an unregistered project is itself the violation. The only meaningful exemptions, under Section 3(2), are small projects: land under 500 square metres or eight apartments or fewer, and projects that had a completion certificate before the Act commenced. Section 11(2) requires every advertisement to prominently carry the registration number and the regulator's website address. The penalty for skipping registration, under Section 59, can extend to ten per cent of the estimated project cost, with imprisonment on continued default.

The ten minute screen

Five steps, in order. The first four are the screen; the fifth is where stage two begins.

A large developer can legitimately launch a project through a brand name that differs from the entity on the registration certificate. What must match is the entity on your booking form and cheque against the registered promoter. A registration also runs to a stated completion date, and HRERA Gurugram separately publishes its Lapsed Projects and Defaulter/Cancelled/Suspended lists on the same site. Thirty seconds in each list is cheap insurance.

What the promoter had to file

Registration is not a rubber stamp. Section 4(2) of the Act forces the promoter to submit a specific set of documents and sworn declarations, and most of them are public on the project's page on the portal. Five documents, five sections, five different questions each answers.

Every item in that table is a sworn filing, not marketing. Read on for what each one actually tells you.

Five years, on affidavit

Section 4(2)(b) requires “brief detail of the projects launched by him, in the past five years, whether already completed or being developed.” This is the single most predictive document in the filing. Count three things: how many projects were launched, how many were actually delivered, and what the gap looks like on the ones still running. A promoter with six launches and one completion is telling you their model is launch funded, whatever the brochure says. Then take those past project names back to the same portal: their pages carry their own declared timelines and quarterly updates, so you can see whether “on schedule” was ever true. Cross reference the Lapsed and Defaulter lists for the same names.

Sanctioned versus rendered

Section 4(2)(c) and (d) require the authenticated approvals, the commencement certificate, and “sanctioned plan, layout plan and specifications of the proposed project.” These are three different documents. The sanctioned plan is what the competent authority approved. The layout plan shows towers, roads, open areas and densities on the parcel. The specifications annexure lists what the flat is actually made of: flooring, fittings, structure, finishes. Put the channel partner's deck next to the filed specifications and read line by line. The Act binds the promoter to the filed versions, and material changes require allottee consent; the brochure binds nobody. If the deck promises Italian marble and the specifications say vitrified tiles, you have learned something in five minutes that most buyers learn at possession.

Clean parcel or listed claims

Under Section 4(2)(l)(B), the promoter must declare on affidavit that “the land is free from all encumbrances,” or else disclose every encumbrance with the “rights, title, interest or name of any party in or over such land.” Read this one slowly. A construction loan secured against the land is normal and will appear here; note who holds the charge, because that lender stands ahead of you if things go wrong. Pending litigation, co-ownership claims, or unclear title chains are a different class of problem. For Haryana parcels you can cross check ownership and mutation history on jamabandi.nic.in; for Noida and Greater Noida, the land is usually authority leasehold, so check the authority's records for dues against the plot, because authority dues have sunk otherwise healthy projects.

Where your cheque actually goes

Section 4(2)(l)(D) is the reason RERA exists: seventy per cent of what buyers pay must sit in a separate account usable only for that project's land and construction cost, withdrawals must be proportional to completion, and each withdrawal must be “certified by an engineer, an architect and a chartered accountant.” The same clause requires the project's accounts to be audited by a CA within six months of every financial year end, verifying that money collected for the project was used for the project.

For you as a buyer this creates a paper trail of the developer's real cash flow: collections, certified progress, and audited utilisation. A project whose withdrawals run ahead of visible construction, or whose audits are missing from the filing, is financing something other than your building. Where the portal publishes these certificates and audit filings, read them; where it does not, asking the promoter for them is a perfectly reasonable pre-booking request, and the reaction to the request is itself information.

Check it against the quarterly filings

“Ninety per cent sold in launch week” is the oldest pressure line in the market. Section 11(1) makes the promoter publish, quarterly, an up to date list of the “number and types of apartments or plots” and garages booked, along with approvals taken and approvals still pending. That means sales velocity is not a matter of trust: it is a public number, updated every quarter, on the project's page. Compare the claim against the filing. While you are there, look at the pending approvals list, because “possession in 2028” means little if environmental clearance or fire NOC is still pending two years in. Missing or stale quarterly updates are themselves a compliance breach, penalised under Section 61, and a project that will not file a one page quarterly return is telling you how it will communicate after it has your money.

The channel partner is on the register too

The person forwarding you the deck is regulated too. Under Sections 9 and 10, real estate agents must themselves be registered with the authority, must quote their registration number, and are barred from facilitating the sale of unregistered projects, on penalty of ten thousand rupees per day. Both HRERA Gurugram and UP RERA have agent search pages. Thirty seconds gives you the broker's registration status. An unregistered channel partner pushing an unregistered project's EOI is not one red flag; it is the whole parade.

Beyond the portal: the sector's own paper

The filing describes the parcel; it does not describe the parcel next door. The sector's land use is set by the published development plan, not by the sales gallery's diorama. For Gurugram and Sohna, the development plans are published by the Town and Country Planning Department at tcpharyana.gov.in, and GMDA's own site carries the infrastructure works actually sanctioned around the sector. For Noida and Greater Noida, the master plan and sector schemes are on the respective authority sites. Ten minutes with the development plan answers the questions the sales team answers with adjectives: what the “green view” plot is actually zoned as, whether the 24 metre road on the map exists or is proposed, and what is planned between the project and the highway it advertises.

The ten per cent rule, before any EOI

Section 13(1) is an absolute ceiling, not a guideline: a promoter “shall not accept a sum more than ten per cent of the cost of the apartment, plot, or building as an advance payment or an application fee” without first entering into a written agreement for sale, and registering it. An EOI against a registered project, within the ceiling, with refund terms in writing, is a normal sales mechanism. An EOI for a project absent from the registry is the promoter operating in the exact window Section 3 was written to close: no approved plans on record, no declared completion date, no separate account, no regulator watching.

One afternoon

Stage one takes ten minutes and eliminates the disqualified. Stage two, done honestly, takes an afternoon: the track record, the specifications against the brochure, the land affidavit, the withdrawal certificates, the quarterly numbers, the agent's registration, the development plan. Every document in that list is either free on a government portal or something a legitimate promoter can hand over without hesitation. In the first half of 2026, HRERA Gurugram cleared 51 projects comprising 16,727 units, roughly ₹34,000 crore of investment, with 11 large projects accounting for about ₹25,000 crore of it. There is more genuine registered supply in NCR than ever. The afternoon of reading is how you tell it apart from the noise.

If you are evaluating a purchase in Gurgaon or Noida and want a second pair of eyes on a project's paper trail, Akhut Estates advises buyers directly: akhut.in/contact.

• Section 3, RERA 2016 (bare act text)
• Section 4, RERA 2016: contents of a project registration filing
• Section 11, RERA 2016: promoter duties incl. quarterly disclosure
• Section 13, RERA 2016: the ten per cent ceiling
• Sections 9 and 10, RERA 2016: agent registration
• HRERA Gurugram, Search Projects
• UP RERA
• DTCP Haryana (development plans, licences)
• Haryana Jamabandi (land records, circle rates)
• Business Today, 16 July 2026: Gurugram RERA clears 51 projects in H1