The 70% rule and MahaRERA's three bank accounts, explained for QPR season

Most questions in a QPR review come back to one number: did 70% of what allottees paid reach the designated account? Since July 2024, MahaRERA has made that easier to check and harder to get wrong, by requiring three bank accounts for every project.

The rule behind it

Section 4(2)(l)(D) of the Real Estate (Regulation and Development) Act, 2016 requires a promoter to declare that 70% of the amounts realised from allottees will be deposited in a separate account and used only for the cost of land and construction of that project. Withdrawals must be in proportion to the completion of the project, and must be certified by an engineer, an architect and a practising chartered accountant.

For years, promoters kept the 70% account alongside their ordinary accounts, and the split was made by hand. That made the figure easy to miss and slow to audit.

The three accounts

MahaRERA issued directions on 27 June 2024, effective from 1 July 2024, requiring three accounts for each registered project, held in the same scheduled bank. As summarised by Trilegal and FoxMandal:

Account	Receives	Used for
Collection account	100% of amounts received from allottees	Transfers onward to the other two accounts
Separate (designated) account	70% of every collection	Land and construction cost, interest on project loans, refunds and compensation to allottees
Transaction account	30% of every collection	The promoter’s other expenses for the project

The structure makes the 70% split visible in the bank statements themselves. That is good news for QPR preparation, because the bank becomes the first place to check the figures rather than the last.

Five checks before the CA signs Form 3

The CA’s certificate in Form 3 states amounts collected, cost incurred and withdrawals from the designated account. These checks catch most of the differences that hold it up:

1. Collections in the books equal deposits in the collection account. A booking receipt entered on 31 March but cleared on 2 April shows up as a timing difference. Note it, rather than forcing the figures to agree.
2. The designated account received 70% of the quarter’s collections. Compare cumulative collections with cumulative transfers into the separate account. A shortfall needs an explanation before the QPR is filed.
3. Withdrawals from the designated account match the cost booked. Every withdrawal should map to land or construction cost in the books, and the cumulative withdrawals should stay in proportion to the completion certified in Forms 1 and 2.
4. Nothing in the separate account belongs to another project. Mis-posted receipts are common when one promoter runs several projects with the same bank.
5. Bank charges and interest are recorded. Small entries the bank posts on its own are the most frequent reason for an unexplained difference of a few hundred rupees.

Keep the explanations

A difference you explain this quarter will be asked about again next quarter, and again in the annual Form 5 audit. Write down the reason when you find it: timing, a bank charge, an entry still to be booked, a posting error in the books or at the bank. Your future self, and the CA, will thank you.

ReraQPR runs these checks every time you reconcile. It matches bank lines to book entries, flags a designated-account shortfall against the 70% rule, and keeps every unmatched item in a review queue until someone records why it differs.

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Sources: Trilegal update on MahaRERA’s bank account directions; FoxMandal; Real Estate (Regulation and Development) Act, 2016, section 4(2)(l)(D).