REGULATORY — What you must comply with

Not legal advice. Confirm specifics with a real lawyer before launching.

RERA Act (Real Estate Regulation & Development Act, 2016)

• Mandatory registration for all real-estate developers, builders, agents before any advertising, marketing, booking, or sale.
• Penalty for non-compliance: fines up to 10% of project cost, daily penalties, and imprisonment up to 3 years.
• State-by-state portal variance — every state runs its own RERA portal with different rules, fees, and document requirements.
• Implication for Dwarseva: We cannot just be a "listings board." We must capture each seller's RERA registration number (if applicable — required for projects with more than 8 units or land > 500 sqm) and the project's RERA ID. For owner-resale and individual rentals, RERA generally doesn't apply, but the seller must self-declare and we must store the declaration.
• Source: myHQ RERA guide 2026, RERA national portal.

DPDP Act 2023 (Digital Personal Data Protection Act)

• Substantive provisions effective May 13, 2027 (verified in EVALUATIONS.md).
• Our app handles seller PII (name, phone, photos of their home, Google location), buyer PII (phone, search location), and transacts in revealing one party's identity to the other for ₹5.
• Obligations: explicit consent for each purpose, purpose limitation, data minimisation, breach notification, deletion-on-request, appointed Data Protection Officer if scaled.
• Implication: from Phase 0 onwards, store a documented purpose-limitation + retention + deletion policy. WhatsApp screenshots count as PII storage.

CPA 2019 + IT Rules 2021 (platform liability)

• Listing platforms are "intermediaries" under IT Rules 2021.
• Failure to act on grievances triggers facilitation liability.
• NCDRC has held listing platforms partly liable in 2023-24 orders for fake-listing scams.
• Implication: Dwarseva must have a documented grievance redressal process from day 1, an appointed Grievance Officer, and a 72-hour acknowledgement SLA. Source: RTI Wiki.

GST

• Wallet top-ups = taxable supply (service).
• Must register for GST if turnover crosses ₹20L (₹10L in special-category states).
• Per-user revenue is so low that compliance overhead is a meaningful cost item.
• B2C transactions need invoice-receipt mechanics in the app or via email.

Aadhaar / PAN (KYC)

• Cannot store Aadhaar number per UIDAI; can only verify via OTP through licensed AUA/KUA route, or store last-4 digits with masked image.
• PAN can be stored with consent.
• Property tax receipts can be uploaded as proof of ownership.

Payments (Razorpay specific)

• RBI guidelines for prepaid payment instruments (PPI) — if our wallet stores customer balance, we may inadvertently be operating a closed-loop PPI which has compliance requirements.
• Safer pattern: every top-up is consumed immediately as listing fee or contact reveal. Don't carry balance > a few days.
• Validate with Razorpay's compliance team before launch.

Local police / building society / municipality

• In Tier-3 cities especially, some societies require their secretary's NOC before listing. Not legally required but socially required.
• Some states' RERA requires the carpet-area-vs-built-up-area declaration to be on the listing itself.

What we owe users (T&C minimum)

• Clear pricing per the CATALOG.
• Refund policy for failed reveals (buyer pays ₹5, listing turns out fake → refund + investigation).
• 14-day no-quibble seller deactivation refund (any wallet balance left, returned).
• Grievance redressal contact + SLA.
• Privacy notice (DPDP-compliant).

Phase 0 minimum compliance checklist

• One-page T&C drafted, reviewed by a real lawyer.
• One-page privacy notice covering DPDP basics.
• Grievance Officer email + 72-hour SLA documented.
• Razorpay account verified, PPI question answered.
• GST registration done if any near-threshold projection.
• State RERA portal bookmarked + reviewed for the chosen Tier-3 city.
• Data retention + deletion process documented even though only Google Sheets.