Mumbai's OC Amnesty Scheme Is Stuck at the Starting Line. Here's Why Your Society Shouldn't Wait

If you own a flat in an older Mumbai building, there is a chance it never received an Occupation Certificate. You may have lived there for twenty years. You may pay your property tax on time and keep the society running smoothly. And still, that one missing piece of paper can make a home loan harder, a sale slower, and your bills higher.

So when BMC opened an amnesty route for these buildings, a lot of families breathed out. Two months on, though, very few have actually stepped through the door. I want to walk you through what has been reported this week, why the calendar matters more than people realise, and what I'd do if it were my own building.

What is happening with the OC amnesty scheme right now?

On 7 November 2026, The Realty Today reported that BMC had received 97 registrations under the OC amnesty scheme, but only four of those had submitted the full set of documents needed for processing. The same report says BMC plans awareness camps across the city with NAREDCO and PEATA (the Practising Engineers, Architects and Town Planners Association) to explain the conditions and paperwork.

A few days earlier, the Free Press Journal reported on 3 November that only four societies had applied so far, one each from Mahim, Mulund, Dadar-Naigaon and Borivali. The reason given was technical trouble uploading documents on BMC's AutoDCR portal, where these applications are filed.

At a PEATA awareness programme covered in that report, Mumbai Suburban Minister Ashish Shelar said, "It is our duty to provide solutions to citizens residing legally in flats purchased by their hard earned money." BMC's Development Plan chief engineer Sunil Rathod said the September guidelines cover BMC buildings only, that SRA and MHADA could issue their own procedures, and that fire safety and other compliances cannot be waived.

My take: the policy exists, but the plumbing is still being fixed. That is frustrating. It is also exactly the moment when well-prepared societies get ahead.

Who can apply for the OC amnesty scheme in Mumbai?

Based on what has been reported, the broad conditions are:

• Type of building: residential buildings, schools and hospitals.
• Occupation date: the building must have been occupied before 17 November 2016.
• Flat size: for the financial concessions, individual units generally need to be up to 80 sq m carpet area, which works out to roughly 861 sq ft.
• Original approvals: the building needs a valid IOD and approved plans, and a Commencement Certificate.
• How to apply: online on AutoDCR, through an architect or licensed surveyor.

Two important limits. First, the scheme does not regularise illegal construction; buildings still have to meet planning and safety requirements. Second, as the Free Press Journal noted, the penalty for commercial use is not waived. If your building needs its OC from SRA or MHADA rather than BMC, you will have to wait for those bodies to issue their own procedures.

When does the penalty waiver end?

This is the part I'd circle in red. According to PEATA, as reported by the Free Press Journal on 5 November, nil penalty applies only up to 8 March 2027, and a 50% penalty applies up to 8 September 2027, counted from the date of BMC's guidelines. PEATA president Yomesh Rao told the paper earlier in the week that after one year the full penalty applies, and that societies have only about four months left in the penalty-free window.

Four months sounds like plenty. It isn't, once you count what goes into a file: old approvals, an architect's survey, fire-safety compliance, and NOCs that can take weeks on their own. And the portal itself is still settling down.

Why are so few societies applying?

From the two Free Press Journal reports, the main hurdles are practical rather than legal:

• Portal problems. Applicants, including individual flat owners, have had trouble uploading documents on AutoDCR.
• Partial OC buildings. Residents of Willington Heights in Tardeo, a 34-storey building with a partial OC, told the paper the system does not let partial-OC buildings apply. Mr Rathod said BMC has written to the state Urban Development Department and expects relaxations "within a couple of months".
• Developer NOCs. An NOC from the original developer or owner is still required, which is hard when a developer has disappeared or is in litigation.
• Other NOCs. PEATA flagged that fresh NOCs may be needed from bodies such as the Airports Authority, Railways and coastal zone authorities, and that CRZ cases cannot be regularised at all.
• Pending cases. Where court or ACB matters are pending, no OC is issued until there is an order, even if the dispute isn't about your flat.
• Individual applications. BMC has asked the state for clarity on how individual members can apply.

Why does an OC matter so much for a flat owner?

Mr Rao told the Free Press Journal that people without an OC pay double water tax and assessment, and that a building without an OC lives under the threat of demolition, FIR and eviction. Beyond that, buyers and banks look for an OC, so its absence can slow a resale or a home loan.

We've seen how small paperwork gaps can hold up a deal. In one Kandivali East resale we handled, the buyer's bank found an old agreement on the flat that had since been cancelled, and paused the loan. We put together the cancellation papers the bank asked for and kept the buyer, the seller and the bank moving on one timeline. A missing OC is a far bigger gap than that, which is why I'd treat this window seriously.