Redevelopment Is 15% of Mumbai Sales: When Such Projects Need RERA, and Who It Protects
With redevelopment making up 15 per cent of Mumbai housing sales in 2025 to H1 2026, according to a JLL and NAREDCO Maharashtra report, this guide uses MoHUA's July 2025 RERA FAQ to explain when a redevelopment project needs RERA registration, why buyers of sale flats count as allottees, and what that means for parking, amenities and interest.
15 per cent. That is the share of Mumbai housing sales that came from redevelopment projects in 2025 and the first half of 2026, according to a JLL and NAREDCO Maharashtra report released at the REIIS 2026 summit and reported by NBM&CW on 4 September 2026. In 2016 to 2021 the figure was 6 per cent.
For a buyer, a redevelopment project looks like any other new launch: a sales office, a brochure, a price per square foot. But it carries two groups of people, existing members getting rehab flats and new buyers paying for sale flats, and the rules that protect each group differ. The Ministry of Housing and Urban Affairs' FAQs on the RERA Act, dated July 2025, answer the questions that matter most to the second group.
The short answer. MoHUA's FAQ says section 3(2)(c) exempts from registration only renovation, repair or redevelopment that does not involve marketing, advertising, selling or new allotment. A redevelopment project that sells new flats is outside that exemption, and section 3(1) requires registration before any advertising, booking or sale. If you buy such a flat, or buy it on resale before completion, you are an allottee under section 2(d), with the same interest rate rule as the promoter and the same protection over open parking and community facilities. The trade-off: RERA protects you as a sale-flat buyer, but existing members' rehab terms are usually set in their own agreement with the developer, so delays in rehab can still affect your timeline.
When does a redevelopment project have to register under RERA?
MoHUA's FAQ lists three exemptions under section 3(2). The third covers projects for renovation or repair or re-development which do not involve marketing, advertising, selling or new allotment of any apartment, plot or building. The other two cover small projects, of not more than 500 square metres or not more than eight apartments including all phases, and projects that received a completion certificate before RERA commenced.
The FAQ also says that under section 3(1), the promoter must register the project before any advertising, marketing, booking, selling, offering for sale or inviting persons to purchase. Read together, a Mumbai redevelopment that only rebuilds members' homes may sit within the exemption, but one that sells new flats to the public does not get the benefit of section 3(2)(c).
That matters because, as the same report notes, the scale is large: more than 1,000 redevelopment projects since 2020 and over 1,600 active self-redevelopment proposals, with redevelopment making up 13 per cent of the city's residential supply.
| Question | MoHUA FAQ answer | Provision cited |
|---|---|---|
| Is redevelopment exempt from registration? | Only if it involves no marketing, advertising, selling or new allotment | Section 3(2)(c) |
| When must a project register? | Before any advertising, marketing, booking, selling or offer for sale | Section 3(1) |
| Is a resale buyer an allottee? | Yes, through transfer or sale; a tenant is not | Section 2(d) |
| Can open parking be sold? | No, open parking areas are part of common areas | Section 2(n) |
| Is the default interest rate the same both ways? | Yes, the rate payable by promoter and allottee is the same, set in the Rules | Explanation to section 2(za) |
Where is Mumbai's redevelopment concentrated?
The JLL and NAREDCO Maharashtra report, titled "Redevelopment in Mumbai: The Inflection Point", gives a sense of where buyers are most likely to meet these projects. As reported by NBM&CW, five locations, Borivali, Malad, Andheri, Vikhroli and Goregaon, account for around 36 per cent of projects since 2020. The Western Suburbs hold 22.4 per cent of the city's ageing stock and South Mumbai 14.2 per cent.
The report also counts about 13,500 cessed buildings needing urgent replacement and 1,202 active slum rehabilitation projects covering 3,21,858 hutments. It notes that the consent threshold dropped to 51 per cent under DCPR 2034, which provides up to 4.0 FSI for cluster and slum projects. These are market and policy figures from a private report, not RERA data, but they show how common redevelopment has become in the city.
What if the redevelopment project started before RERA?
MoHUA's FAQ says ongoing or incomplete projects are covered. Under the first proviso to section 3(1), promoters of ongoing projects that had not received a completion certificate needed to register within three months of the Act's commencement. Projects that received a completion certificate before RERA commenced are not required to register, under section 3(2)(b).
For a buyer, the test is simple: if the building you are buying into is still under construction and new flats are on sale, look for its registration, whatever year the redevelopment began.
Are you protected if you buy a sale flat on resale before completion?
Yes. MoHUA's FAQ says that under section 2(d), an allottee includes a person who acquires the apartment or plot through transfer or sale, but does not include a person to whom the plot or apartment is given on rent. So a buyer who takes over an under-construction sale flat from the original booker steps into allottee status, while a tenant does not.
In practice, that means checking that the transfer is recorded by the promoter and that your name appears on the agreement and receipts. The rights you inherit, such as possession on the agreed date or interest for delay, attach to the allotment you are taking over, so read the original agreement for sale carefully.
What do common areas mean in a redevelopment project?
MoHUA's FAQ says section 2(n) defines common areas to include open parking areas, so open parking areas cannot be sold to allottees. It also says common areas include community and commercial facilities, which are an integral part of the project to be handed over to the association of allottees.
A garage is treated differently. The FAQ says section 2(y) defines a garage as a place within a project having a roof and walls on three sides for parking any vehicle, not including unenclosed or uncovered parking such as open parking areas, and that a garage can be sold to the allottee independent of the apartment.
In redevelopment, where parking is often tight, ask whether the space offered to you is a garage or open parking, and get it described in the agreement. The same question applies to any society or project you are comparing, including a new launch such as The Prestige Place in Kanjurmarg.
What interest applies if you or the developer pay late?
MoHUA's FAQ says that, as per the Explanation to section 2(za), the rate of interest payable by the promoter or the allottee in case of default is the same, and that the rate is specified by the appropriate Government in the Rules. For Mumbai, that means the Maharashtra rules set the rate, and the same rate applies whether you pay an instalment late or the developer delivers late.
Because the rate is set by rules, check the current Maharashtra rule and the interest clause in your agreement before you sign, and keep a record of every payment.
What about the society's members and the developer?
RERA's allottee protections described above are framed around the sale of apartments. The relationship between a housing society and its developer is usually set by their development agreement, and disputes between them can raise different questions, as our report on the MIG Bandra redevelopment ruling showed.
For a sale-flat buyer, the practical point is that a stalled rehab component can delay the whole building. We reported one such dispute in the Nehru Nagar, Kurla case, where sale-flat buyers' position became an issue when a new developer came in.
What should a Mumbai buyer check before booking a redevelopment flat?
Use MoHUA's answers as your checklist, alongside your lawyer's title review:
- Confirm the project is registered with MahaRERA before you pay, since section 3(1) requires registration before booking or sale.
- Match the registration number in the advertisement, brochure or SMS with the project record, since the FAQ says SMS and email solicitations count as advertisements.
- Ask whether your unit is a sale flat or a rehab flat, and get the description in writing.
- Check whether the parking offered is a garage or open parking, since open parking is a common area that cannot be sold.
- Read the interest clause and confirm it matches the rate set in the Maharashtra rules.
- If buying on resale before completion, make sure the promoter records the transfer so you are an allottee under section 2(d).
- Ask the developer for the status of the society's development agreement and the rehab component's timeline.
Frequently asked questions
Does a Mumbai redevelopment project need RERA registration?
MoHUA's July 2025 FAQ, citing section 3(2)(c), says registration is not required for renovation, repair or redevelopment that does not involve marketing, advertising, selling or new allotment of any apartment, plot or building. Where new flats are marketed or sold, the exemption in that clause does not apply.
Is a person who buys an under-construction flat on resale an allottee under RERA?
Yes. MoHUA's FAQ says that under section 2(d) an allottee includes a person who acquires the apartment or plot through transfer or sale, but does not include a person to whom it is given on rent. A resale buyer of an under-construction flat therefore steps into allottee status.
Can a builder sell open parking in a Mumbai redevelopment project?
MoHUA's FAQ says section 2(n) defines common areas to include open parking areas, so open parking areas cannot be sold to allottees. It says a garage, defined in section 2(y) as a place with a roof and walls on three sides, can be sold independently of the apartment.
How big is redevelopment in Mumbai's housing market?
A JLL and NAREDCO Maharashtra report released at REIIS 2026, as reported by NBM&CW on 4 September 2026, put redevelopment at 15 per cent of Mumbai housing sales for 2025 to H1 2026, up from 6 per cent in 2016 to 2021, and 13 per cent of residential supply.
This article summarises MoHUA's July 2025 FAQs on the RERA Act and press reporting of a JLL and NAREDCO Maharashtra report, for information. It is not legal advice; MoHUA's FAQ itself notes that it is general guidance, and the Act and Maharashtra rules govern.
Last updated 2026-11-12. PropNewz Team.
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