IOD, commencement certificate, OC: what each Mumbai redevelopment approval proves, and the dates to check

Rules and rates as of 12 October 2026.

At some point in a Mumbai redevelopment, the project management consultant (PMC) appointed by your society will put a file of approvals in front of the managing committee. Most members nod and sign. This guide explains what each of the main documents actually proves under Maharashtra law, what it does not prove, and which dates on each page you should copy into your own notebook.

The legal frame in two sentences

In Maharashtra, nobody may develop land without permission from the planning authority, applied for under section 44 of the Maharashtra Regional and Town Planning Act, 1966 (MRTP Act). Section 45 says that permission, whether unconditional or with conditions, is to be given in the form of a commencement certificate. So in law the commencement certificate (CC) is the building permission itself; the other papers either lead up to it or follow it.

Document 1: the IOD (Intimation of Disapproval)

In Greater Mumbai the municipal corporation (MCGM) first issues an Intimation of Disapproval under section 346 of the Mumbai Municipal Corporation Act. Despite the name, it is not a rejection. The Bombay High Court, in Sea Kunal Corporation Private Limited vs The Municipal Corporation of Greater Mumbai (Writ Petition No. 3217 of 2018, Ranjit V. More and Bharati H. Dangre, JJ., 27 February 2019), described an IOD that "stipulated certain conditions to be complied with before the commencement of work stage wise", with the CC issued afterwards on those conditions. Where MHADA's Building Permission Cell is the planning authority, the equivalent letter is called an IOA (Intimation of Approval).

What it proves: the plans have been scrutinised and the authority has listed what must be done before and during construction, typically no-objection certificates from other departments, payments and undertakings. What it does not prove: that anyone may start digging. Work begins only on a CC.

Dates to note: the IOD date, the date of the plans it approves, and each condition marked "before CC", "before plinth" or "before OC". Ask the PMC for a compliance sheet showing every condition against its status.

Document 2: the commencement certificate, and why it comes in stages

Mumbai CCs are commonly issued in instalments. A CC issued by MHADA's Building Permission Cell on 29 June 2026 for a redevelopment under regulation 33(5) of the Development Control and Promotion Regulations for Greater Mumbai 2034 (DCPR 2034) is a good illustration. It was granted "upto plinth for Phase-I", stated "This CC is valid upto 28 June, 2027", and said it "shall be re-endorsed after obtaining IOA for work beyond plinth". It also said no new building may be occupied until occupancy permission is granted, and that the authority may revoke the CC if work departs from the sanctioned plans, a condition is broken, or the CC was obtained by misrepresentation.

That is the pattern you will see: a plinth CC first, then a further CC (an endorsement extending the permission above plinth, sometimes floor by floor) once the authority is satisfied about the plinth and the next set of conditions.

What it proves: legal permission to build up to the level written on it, as per the plans it cites. What it does not prove: permission for any floor above that level, or that the building as built will match the plans.

The clock in section 48

Section 48 of the MRTP Act says every development permission remains in force for one year from receipt of the grant, "and thereafter it shall lapse". The planning authority may extend it year by year, but the extended period "shall in no case exceed three years". And if the development is not completed up to plinth level (or, where there is no plinth, the upper level of the basement or stilt) within the year or the extension, "it shall be necessary for the applicant to make application for fresh permission". In plain terms: a CC that sits unused, or a project stuck below plinth, can lose its permission.

Dates to note: the CC date, the "valid up to" date, the level up to which it is granted, and the date and level of each further CC or re-endorsement.

Document 3: the occupation certificate (OC)

The Real Estate (Regulation and Development) Act, 2016 (RERA) defines an occupancy certificate as the certificate, whatever local law calls it, "issued by the competent authority permitting occupation of any building". Under section 11(4)(b) the promoter is responsible for obtaining the completion certificate or occupancy certificate and making it available to allottees or their association. The older Maharashtra Ownership Flats Act, 1963 (MOFA) says in section 3(2)(i) that a promoter must not allow persons to enter into possession until a completion certificate has been duly given by the local authority.

What it proves: the authority permits people to live in the building (or the part named on it). What it does not prove: that every floor or wing is covered. Read which wings and floors it lists. For a buyer, RERA section 19(10) requires the allottee to take physical possession within two months of the OC being issued.

Dates to note: OC date, the floors and wings covered, and any conditions left open.

The three documents side by side

Document	Legal hook	Proves	Does not prove	Date to write down
IOD / IOA	Section 346, Mumbai Municipal Corporation Act (MCGM); IOA for MHADA	Plans scrutinised; conditions listed	Permission to start work	Issue date; plan date; each condition's stage
CC up to plinth	MRTP Act ss. 44, 45	Permission to build to plinth	Permission above plinth	Issue date; "valid up to"; level granted
Further CC / re-endorsement	MRTP Act s. 45; CC conditions	Permission to the next stated level	That the finished building matches the plans	Date; level or floors covered
Occupation certificate	RERA ss. 2(zf), 11(4)(b); MOFA s. 3(2)(i)	Occupation permitted for the parts listed	Coverage of unlisted wings or floors	Date; wings and floors covered

A worked example (illustrative)

The society, dates and figures below are invented to show how the dates fit together; they are not drawn from any real project.

A 40-member society signs a development agreement in which the developer pays each member transit rent of ₹45,000 a month until possession, and promises the OC by June 2027. The PMC's file shows:

• IOD: 15 January 2024, listing conditions to be met before CC and before plinth.
• CC up to plinth: 10 June 2024, valid up to 9 June 2025.
• Plinth reached: March 2025, inside the one-year window, so section 48's fresh-permission trigger does not arise.
• Further CC up to the full height: 20 May 2025.
• Promised OC: June 2027. Assume it actually arrives in March 2028, nine months late.

Transit rent at stake for those nine months:

Total = members × monthly rent × months of delay = 40 × ₹45,000 × 9 = ₹1,62,00,000

Item	Calculation	Amount
Monthly transit-rent bill, whole society	40 × ₹45,000	₹18,00,000
Nine-month delay, whole society	₹18,00,000 × 9	₹1.62 crore
Nine-month delay, one member	₹45,000 × 9	₹4,05,000

If the agreement ties rent to "possession" rather than to a calendar date, the developer carries that ₹1.62 crore; if rent stops on a fixed date, the members do. Either way, the date that matters is the OC, not the date the building looks finished, because the CC conditions quoted above forbid occupation before occupancy permission. The same arithmetic tells you how much a bank guarantee or rent escrow would need to cover a slip of a given length.

Where to check independently

A registered project's promoter must file "an authenticated copy of the approvals and commencement certificate" with its RERA registration application (section 4(2)(c)), and must update on the regulator's website, every quarter, "the list of approvals taken and the approvals which are pending subsequent to commencement certificate" (section 11(1)(d)). Comparing the MahaRERA project page with the PMC's file is a free cross-check. Questions on the society's rights under the development agreement belong with the society's advocate.