By Arosh John | Founder – John Real Estate (MahaRERA Reg. No. A51700001835) | Editor-in-Chief – Thane Real Estate News (TREN)
Thane–MMR | October 2025
When a developer avails a project finance loan, the lending institution secures its interest by creating a charge on the project land parcel and future receivables. Under the Companies Act, this charge must be officially registered with the Registrar of Companies (ROC) and remains visible as an Active Charge on the MCA portal until the loan is fully repaid and a Satisfaction of Charge (Form CHG-4) is filed.
Once the loan is closed, the developer is required to file Form CHG-4 within 30 days. Only after this filing does the ROC update the charge status to “Satisfied”, indicating that the project is no longer encumbered under that registered mortgage at the company level.
How ROC Charge Status Can Be Viewed
- The charge status can be checked on the MCA/ROC portal → View Charges section by searching the developer’s registered company name.
- The public can view whether a charge is Active or Satisfied without any fee.
- Downloading the certified charge document or CHG-4 satisfaction acknowledgement requires a nominal MCA fee.
- Important Clarification: The ROC portal does not display project names, tower details, survey numbers or flat identifiers. It only records a company-level financial charge.
The link between a specific flat and that ROC charge is established only when the bank issues a Unit-Level Release NOC referencing the ROC Charge ID.
ROC vs CERSAI – Two Separate Registries
| Registry | Law Applicable | Filed By | What It Represents |
|---|---|---|---|
| ROC (MCA Portal) | Companies Act | Developer (CHG-1 / CHG-4) | Company-level mortgage — Active or Satisfied status |
| CERSAI | SARFAESI Act | Bank/NBFC | Mortgage/security interest — Active or Released |
Even if some units are sold or part of the loan is repaid, ROC will continue to show the charge as Active until full loan closure and filing of CHG-4.
MahaRERA Disclosures – Transparency, Not Legal Clearance
Developers are required to declare existing encumbrances and project borrowings at the time of MahaRERA registration. However:
- MahaRERA functions as a declaration platform and does not certify loan closure or charge release.
- The 70% RERA-designated account cannot be lien-marked, but the land parcel may continue to remain under mortgage until ROC/CERSAI satisfaction is completed.
Understanding CHG-4 – Full Release of Project Charge
When a developer fully repays the project loan:
- The bank issues a Loan Closure/Release Letter.
- The developer files Form CHG-4 with ROC.
- ROC verifies and updates the status to “Satisfied”.
- Only at this stage is the project officially considered free from that registered mortgage under the Companies Act framework.
ROC Project Charge vs Flat-Level NOC — Two Different Legal Layers
| ROC Project Charge (Company-Level) | Bank NOC (Flat-Level Release) |
|---|---|
| Charge exists on the entire project land and receivables. | Bank issues a Unit-Level NOC releasing a specific flat. |
| Visible on the ROC portal as Active or Satisfied. | Not reflected on ROC — exists only as a bank-issued document. |
| Cleared only when the entire loan is repaid and CHG-4 is filed. | Issued individually for each flat during sale or loan disbursement. |
| Remaining unsold units remain under charge. | Once NOC is issued, that specific flat is no longer under mortgage, even if ROC still shows an Active Charge for the larger project. |
Practical Note for Self-Funded Buyers:
If you are buying without a home loan, the developer may not automatically obtain the Unit-Level Release NOC for your flat. It is advisable to formally request this NOC after registration, as coordinating with the project lender typically takes 7–21 working days. Obtaining it early ensures your flat is clearly released from the project charge and avoids delays during future resale or refinancing.
What Buyers in Thane–MMR Should Practically Do
- Ask the developer upfront whether the project is under a registered charge.
- If you are taking a home loan, your bank will automatically require a Unit-Level NOC referencing the ROC Charge ID.
- If you are self-funding, proactively request this NOC after your agreement registration so that it is formally recorded that your flat has been released from the charge.
- Retain the Unit NOC carefully, as it is the key document proving that your specific flat is not under mortgage, even if ROC still shows an Active Charge at the project level.
Why This Matters in Thane–MMR Transactions
In active resale and mortgage-backed markets such as Ghodbunder Road, Majiwada, Kolshet, Pokhran Road and the wider Dombivli–TDLR corridor, transactions often get delayed because buyers assume that ROC charge status automatically reflects unit-level clarity. In reality, the Unit-Level NOC is the decisive document that confirms individual release. Securing it early protects resale liquidity, bank loan approvals and NRI funding readiness.
About the Author
Arosh John is a MahaRERA-registered real estate consultant (Reg. No. A51700001835), Founder of John Real Estate, and Editor-in-Chief of Thane Real Estate News (TREN). With over a decade of experience in Thane–MMR real estate across luxury villas, premium resale transactions, NRI advisory and infrastructure-led property investments, he is widely regarded as a leading industry voice for regulatory clarity and transparent real estate practices in Maharashtra.
Disclaimer
This article is for educational purposes for homebuyers, sellers, investors and real estate professionals. It does not constitute legal or financial advice. Property and charge status should always be verified through official sources, including ROC/MCA, CERSAI, MahaRERA and respective lending institutions. All regulatory names and trademarks belong to their respective authorities.
