Approvals Taken, Approvals Pending: Reading a Bengaluru Project's RERA Approval Trail

Open almost any project page on a state RERA portal and, somewhere in the quarterly updates, you will find two lists that most buyers scroll past: approvals taken and approvals pending. The second list is not a red flag by default. The Real Estate (Regulation and Development) Act, 2016 expects some approvals to arrive after construction begins, and it builds a reporting trail around them. For a Bengaluru buyer weighing an under construction flat, learning to read that trail is one of the cheapest pieces of due diligence available.

This guide uses the text of the Act, as published in the Gazette copy of the RE(R&D) Act, 2016 hosted on the Telangana RERA portal. The Act is a central law, so the sections below apply in Karnataka as they do elsewhere; your state's rules and the K-RERA portal decide the exact screens and forms.

The short answer. Under the RERA Act, a promoter must file authenticated approvals and the commencement certificate at registration (Section 4(2)(c)), declare on affidavit that it will take all pending approvals on time (Section 4(2)(l)(E)), and update the list of approvals taken and pending every quarter (Section 11(1)(d)). It is also responsible for obtaining the completion or occupancy certificate and making it available to buyers (Section 11(4)(b)). The trade-off: booking while approvals are pending can mean an earlier entry and more unit choice, but it also means part of the project's legal path is still ahead, so you are relying on the promoter's declaration being kept.

What approvals does a promoter file at registration?

Section 4(2)(c) requires the promoter to enclose with its registration application an authenticated copy of the approvals and the commencement certificate from the competent authority, obtained under the laws applicable to the project. Where the project is to be developed in phases, the same clause requires authenticated copies of approvals and commencement certificates for each phase.

Clause (d) of the same subsection adds the sanctioned plan, layout plan and specifications of the proposed project or phase, and the whole project as sanctioned by the competent authority. Together, these tell you what has been approved, by whom, and for which part of the land. Our earlier guide on the Section 4(2) registration filing checklist walks through the rest of the application.

What does the promoter promise about approvals still pending?

It promises, on affidavit, to get them on time. Section 4(2)(l) requires a declaration supported by an affidavit signed by the promoter or an authorised person. Sub-clause (E) of that declaration states that the promoter shall take all the pending approvals on time from the competent authorities.

That single line matters because it turns a pending approval from an informal assurance into a declared commitment filed with the regulator. It does not tell you which approvals are pending or how long they will take. For that, you need the quarterly list.

Where do I see approvals taken and pending after registration?

On the project's web page on the RERA portal. Section 11(1) requires the promoter, after receiving its login, to create a web page on the Authority's website and enter project details for public viewing. Clause (d) specifically requires a quarterly up to date list of approvals taken and the approvals which are pending subsequent to the commencement certificate. Clause (e) adds a quarterly up to date status of the project.

The phrase subsequent to commencement certificate is the key. The Act anticipates that once construction is permitted to begin, further approvals may still be required as the project progresses. A pending list is therefore normal. What you are looking for is whether items move from pending to taken over successive quarters, and whether the list is updated at all. Our explainer on reading a project's quarterly updates under Section 11 shows how to compare one quarter with the next.

Who is responsible for the completion or occupancy certificate?

The promoter. Section 11(4)(b) says the promoter shall be responsible to obtain the completion certificate or the occupancy certificate, or both, as applicable, from the relevant competent authority as per local laws, and to make it available to the allottees individually or to the association of allottees.

Section 11(4)(a) sets the wider frame: the promoter is responsible for all obligations under the Act, the rules and regulations, and the agreement for sale until conveyance of all apartments to allottees and common areas to the association or competent authority. Our piece on the commencement, completion and occupancy certificates under RERA explains how the three documents fit together.

Here is how the approval trail maps to the Act.

Phases matter too, because approvals and registration attach phase by phase. The Explanation to Section 3 says that where a project is developed in phases, every phase is considered a standalone real estate project and the promoter must obtain registration for each phase. Section 4(2)(c) mirrors this for approvals and commencement certificates.

A larger project may be launched in phases or towers over several years. The approvals that are complete for an earlier tower tell you little about the tower you are buying in. When you check the approvals list, make sure you are looking at the registration and quarterly updates for your phase. A PropNewz project profile, such as our page on Sobha Mullur on Sarjapur Road, can help you identify a project, but the phase level RERA record is the document that answers this question.

How should I read a long pending list before booking?

Read it as a list of questions, not a verdict. For each pending item, ask the promoter what the approval is, which authority grants it, when it was applied for and when it is expected. Note whether the item appeared in previous quarters and whether any items have moved from pending to taken. A list that is updated regularly and shrinks over time tells a different story from one that is unchanged or not updated at all.

It also helps to think about what each approval affects. Some approvals relate to the building itself, others to services like water, power or fire safety, and others to completion. You do not need to become an expert in each one, but you should understand which items stand between the project and its completion or occupancy certificate, since Section 11(4)(b) puts that certificate on the promoter's list of responsibilities. If the answers are vague, that is information too.

Finally, compare the pending list with the completion date the promoter declared at registration and with the possession date in your draft agreement for sale. If a key approval is pending close to those dates, ask how the timeline accounts for it.

What protections apply if approval conditions are not met?

The Act gives the regulator and buyers several levers. Section 7(1) lets the Authority, on a complaint, on its own motion or on the recommendation of the competent authority, revoke a project's registration if it is satisfied that the promoter has defaulted in doing anything required under the Act, rules or regulations, has violated any of the terms or conditions of the approval given by the competent authority, is involved in unfair practices or irregularities, or indulges in fraudulent practices. The Explanation to that clause lists, as one example of an unfair practice, representing that the promoter has an approval or affiliation it does not have.

For buyers, Section 18(1)(b) links directly to this. If the promoter is unable to give possession due to discontinuance of business on account of suspension or revocation of registration, the allottee who wishes to withdraw is entitled on demand to a return of the amount paid with interest at the prescribed rate and compensation. These are remedies, not shortcuts: they involve proceedings and time. That is why checking the approval trail before booking is far easier than relying on enforcement afterwards.

One practical habit follows from the Explanation to Section 7. If a brochure, website or sales pitch says a particular approval has already been obtained, check whether it appears in the approvals taken list for your phase. If it does not, ask the promoter to point you to the document.

What should I do before paying a booking amount?

Use this checklist on the specific phase you plan to buy into.

1. Confirm the RERA registration number for your exact phase or tower, not an earlier one.
2. Open the approvals and commencement certificate filed under Section 4(2)(c) for that phase.
3. Read the latest quarterly list of approvals taken and pending under Section 11(1)(d).
4. Compare it with the previous quarter to see whether any items have moved from pending to taken.
5. Ask the promoter in writing for the expected timeline of each pending approval.
6. Check that the declared completion date and your agreement's possession date allow for those timelines.
7. Keep copies of each quarter's list you read, with the date, so you can track changes later.

Frequently asked questions

Can a RERA registered project still have approvals pending?

Yes. Section 11(1)(d) of the RERA Act requires the promoter to update, every quarter, the list of approvals taken and the approvals which are pending subsequent to the commencement certificate. That wording assumes some approvals may still be pending after registration, which is why the quarterly list is worth reading.

What does the promoter promise about pending approvals?

Section 4(2)(l)(E) requires the promoter's registration application to include a declaration, supported by an affidavit, that it shall take all the pending approvals on time from the competent authorities. Ask which approvals are pending and the expected timeline, and keep the answer in writing.

Who is responsible for getting the occupancy certificate?

Section 11(4)(b) says the promoter shall be responsible to obtain the completion certificate or the occupancy certificate, or both as applicable, from the relevant competent authority as per local laws, and to make it available to the allottees individually or to the association of allottees.

Does each phase of a project need its own approvals?

Section 4(2)(c) requires authenticated copies of the approvals and commencement certificate for the project, and where it is developed in phases, for each phase. The Explanation to Section 3 also treats every phase as a standalone real estate project, so check the approvals for the specific phase you are buying into.

Last updated 2026-10-28. PropNewz Team.