Promoters are required to upload an annual audit report in Form-5 for every registered project within six months from the end of each financial year. Despite several extensions under the Voluntary Compliance Scheme (Order 102 of December 2024, extended via Orders 105 and 105A), many promoters continued to default. Non-compliance leads to closure of the filing window and can trigger suo moto proceedings under Sections 60, 61 and 63 of the RERA Act.

The order introduces separate treatment for past defaults (FY 2017-18 to 2023-24) and future filings (FY 2024-25 onwards):

• Defaulted Form-5 (FY 2017-18 to 2023-24)
  • Final opportunity to submit under VCS-2025 is extended till September 30, 2025.
  • From October 1, 2025, any further delay will attract:
    • Lump sum fee: ₹10,000 (projects <₹25 Cr), ₹25,000 (₹25–50 Cr), ₹50,000 (₹50–100 Cr), and ₹1,00,000 (above ₹100 Cr).
    • Daily Late Processing Fee (LPF): ₹400–₹1,000 per day depending on project cost.
  • The last date to regularise these defaults is March 31, 2026.
  • Failure beyond this will result in freezing of the RERA-designated bank account, exemplary penalties under the Act, and rejection of related project applications until compliance is achieved.
• Future Form-5 (FY 2024-25 onwards)
  • Due date fixed as October 31 of the following year (e.g., Form-5 for FY 2024-25 due by October 31, 2025).
  • Delay beyond due date will attract daily LPF (₹400–₹1,000 per day based on project cost).
  • Late filing permitted only till the end of the next financial year. For instance, FY 2024-25 Form-5 can be filed until March 31, 2026 with applicable LPF.
  • Failure beyond this extended timeline will attract freezing of bank accounts, penalties under Sections 60, 61, and 63, and restriction on project-related applications (extensions, alterations, compliance submissions, etc.).
• Special Provisions
  • Form-5 submission window will no longer be locked on the portal, allowing promoters to file at any time subject to applicable fees.
  • Pending suo moto proceedings: if no final order has been issued, compliance with the new scheme (lump sum fee + Form-5 filing) will lead to withdrawal of proceedings.
  • Final orders already passed will be binding and must be complied with separately.
• Repeal of Earlier Directions
  • Fifteen previous orders and one guidance note issued between 2018 and 2024 (including Order 14 of 2018, Order 31 of 2019, Order 96 of 2024, etc.) stand repealed.
  • Actions or proceedings initiated under repealed orders remain valid and are deemed to continue under the new order.