Was Your Bengaluru Project Started Before RERA? How the Ongoing Project Rule Works

A family is looking at a three bedroom resale flat in a Whitefield tower. The building looks finished, residents have lived there for years, and the seller says the project was launched long before anyone in Bengaluru had heard of RERA. Their lawyer asks a different question: when did the project receive its completion certificate? The answer decides whether the project should be on the regulator's register at all.

The Real Estate (Regulation and Development) Act, 2016 did not stop at projects launched after it took effect. It reached back to projects that were still under way. This guide explains how that rule works, using the Housing Ministry's own FAQs on the Act, and what it means for buyers weighing an older project.

The short answer. According to the Ministry of Housing and Urban Affairs FAQs on RERA, sections 3 to 19 of the Act took effect on 1 May 2017, and promoters of all ongoing projects that had not received a completion certificate had to register them within three months of commencement. Projects that already had a completion certificate before the Act commenced do not need registration. The trade-off: the rule brings many older projects under RERA's protection, but only the completion certificate and its date can tell you which side of the line a project falls on, so a building that looks finished is not proof either way.

Which projects count as ongoing under RERA?

A project counts as ongoing if it had not received a completion certificate when the registration provisions came into force. The Housing Ministry's FAQs say that ongoing or incomplete projects are covered under the Act, and that the first proviso to section 3(1) requires promoters of all ongoing projects which have not received a completion certificate to register their project with the regulator within three months of its commencement.

The timing comes from the commencement dates. The FAQs explain that the Act was published in the Official Gazette on 26 March 2016, and that while some sections took effect on 1 May 2016, sections 3 to 19, section 40, sections 59 to 70 and sections 79 to 80 were notified for commencement with effect from 1 May 2017. Section 3 is the registration requirement, so 1 May 2017 is the reference date for the ongoing project rule.

What matters, then, is not when a project was launched or when its first buyers moved in, but whether it held a completion certificate on that date. A project launched in 2014 that was still awaiting its completion certificate in May 2017 was, on the FAQs' reading, an ongoing project that needed to register.

Location matters too. The FAQs explain that section 3(1) requires projects within a planning area to be registered, and that the second proviso lets the regulator, with the requisite permission of the local authority, direct a promoter to register a project beyond the planning area in the interest of allottees.

What does the rule require of an ongoing project?

Registration with the regulator, on the same footing as a new project. The FAQs explain that section 3(1) requires a promoter to register a project with the respective Real Estate Regulatory Authority before any advertising, marketing, booking, selling, offering for sale or inviting persons to purchase in the project. For ongoing projects, the first proviso gave promoters three months to complete that registration.

Registration brings the project inside the Act's framework. The FAQs describe how sections 4 and 11 require detailed disclosures on the regulator's website for public viewing, and how section 11 requires promoters to update project information on a quarterly basis. For a buyer, that means an ongoing project that registered should have a public record you can read.

This matters for resale buyers as well as first buyers. The FAQs explain that, under section 2(d), an allottee includes a person who acquires an apartment or plot through transfer or sale. A family buying an under-construction flat from an earlier buyer in an ongoing project steps into the position of an allottee, with the same interest in the project's registration and disclosures.

The rule also explains why some projects in Bengaluru that began years ago still appear on the regulator's portal with registration numbers and declared completion dates. We set out what happens to projects that never registered in our guide to unregistered projects under sections 3 and 59.

Which older projects are outside the rule?

Three kinds of project fall outside the registration requirement, according to the FAQs' summary of section 3(2). First, projects where the area of land proposed to be developed does not exceed 500 square metres or the number of apartments proposed does not exceed eight, inclusive of all phases. Second, projects where the promoter received a completion certificate before the Act commenced. Third, renovation, repair or redevelopment that does not involve marketing, advertising, selling or new allotment of any apartment, plot or building.

The second exemption is the one that matters most for older projects. The FAQs state plainly that projects which received a completion certificate before RERA commenced are not required to be registered. The table below shows how the rule sorts some common situations; the scenarios are illustrative.

Treat each exemption as something to confirm on paper. The size exemption counts all phases together, so a small first phase of a larger plan does not qualify on its own. And the renovation exemption falls away once units are marketed, sold or newly allotted.

Why does the completion certificate decide the question?

Because it marks the legal end of the project under the Act. The FAQs explain the difference between the two certificates the Act defines. The occupancy certificate relates to occupation of the apartment or building, which has provision for civic infrastructure such as water, sanitation and electricity and is habitable. The completion certificate relates to the completion of the entire project, certifying that it has been developed according to the sanctioned plan, layout plan and specifications approved by the competent authority.

That distinction matters for older projects. A tower can be occupied for years while the wider project, with its later phases or common facilities, remains incomplete. Under the FAQs' reading, it is the completion certificate for the project, not residents moving in, that takes a project outside the ongoing category.

The FAQs add a practical note. Both definitions use the words "by whatever name called", so if a State issues only one certificate that covers both aspects, that would suffice for the Act's purposes. Ask what document the local authority issued, what it certifies and the date it was issued, rather than relying on its title alone. Our guide to occupancy and completion certificates in Bengaluru covers the documents in more detail.

How can a Bengaluru buyer check an older project's status?

Start with the certificate and work outward. If the seller or builder can show a completion certificate dated before 1 May 2017, the project sits outside the registration requirement on the FAQs' reading. If they cannot, check the regulator's portal. If you are comparing such a project with a newer one, such as Century Midtown on our project pages, apply the same checks to both. These steps keep the exercise systematic.

1. Ask the seller or builder for the completion certificate and note the date it was issued.
2. Check what the certificate covers: the whole project, one phase or one building.
3. If there is no completion certificate dated before 1 May 2017, search the Karnataka RERA portal for the project.
4. Match the promoter's name, project name and address on the portal with your documents.
5. Read the declared completion date and the latest quarterly updates on the project's portal page.
6. Check whether the project falls within the 500 square metre or eight apartment exemption.
7. Take legal advice if an ongoing project has no registration and no clear exemption.

If an ongoing project you are considering does not appear on the portal and no exemption applies, treat that as a reason to pause, not a paperwork detail. Ask the builder to explain in writing, and do not pay until the answer is clear.

None of this replaces the usual title and approval checks on any purchase. It simply tells you whether the regulator's register should hold a record of the project, and whether the Act's disclosures are there for you to read.

What do Bengaluru buyers ask about older projects and RERA?

Does RERA apply to projects that started before 2017?

Yes, if they were ongoing. The Housing Ministry's FAQs say ongoing or incomplete projects are covered, and that promoters of all ongoing projects which had not received a completion certificate had to register them with the regulator within three months of the provision's commencement.

Which older projects did not need RERA registration?

Under section 3(2)(b), as the Housing Ministry's FAQs explain, registration is not required where the promoter received a completion certificate for the project before RERA commenced. Projects within the small project and renovation exemptions in section 3(2) are also outside the registration requirement.

When did RERA's registration provisions take effect?

The Housing Ministry's FAQs say sections 3 to 19, section 40, sections 59 to 70 and sections 79 to 80 were notified for commencement with effect from 1 May 2017. Section 3 is the provision that requires projects to be registered with the regulator.

How can I check whether an older Bengaluru project is RERA registered?

Search the Karnataka RERA portal by project and promoter name, and ask the seller or builder for the completion certificate with its date. If the project had no completion certificate when RERA took effect and is not exempt, it should appear on the portal.

Last updated 2026-10-19. PropNewz Team.