regulatory

Synthesiscanonicalverified 2026-07-22

SYNTHESIS.REGULATORY

REGULATORY — What you must comply with

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

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 Seedha Ghar: 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.

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.

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: Seedha Ghar must have a documented grievance redressal process from day 1, an appointed Grievance Officer, and a 72-hour acknowledgement SLA. Source: RTI Wiki.

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.

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.

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.

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.

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).