Telangana 22-A Tags May Enter Developer Audit Notes Next

Telangana 22-A Tags are likely to move from a buyer-side title check issue to a developer finance and audit disclosure issue. With 147,934 prohibited properties recorded under Section 22-A, lenders, statutory auditors and project financiers may start asking developers to clearly disclose whether any land parcel, access road, pooled land, mortgage security or future phase falls under a prohibited category.

For Hyderabad’s development market, this is not a small compliance footnote. We have seen buyers in Kokapet, Narsingi, Tellapur, Patancheru, Ghatkesar, Maheshwaram and Shamshabad becoming sharper about survey numbers, pahani extracts, Dharani records and SRO checks. Now, the same pressure may reach boardrooms, audit files and bank appraisal notes.

In our view, 22-A risk is moving from “legal due diligence” to “financial disclosure”. That change can affect borrowing costs, project timelines and buyer confidence.

Telangana 22-A Tags and the 147,934-property overhang

Section 22-A properties are those where registration is prohibited or restricted. These may include government lands, assigned lands, endowment lands, wakf lands, court-disputed parcels, ceiling surplus lands or other categories notified by the authorities. The database count now stands at 147,934 prohibited properties, a number large enough for auditors and financiers to treat it as a material market risk.

Earlier, many homebuyers would check only the sale deed, link documents and Encumbrance Certificate. That is no longer sufficient in fast-moving corridors. A land parcel may have clean-looking private documents but still trigger a prohibited property flag at the SRO or in government records. Before paying token advance, buyers should run a Section 22-A Prohibited Property Check, verify past transactions through Encumbrance Certificate Search, and match survey details using the Survey Number Finder.

Developers will also face the same scrutiny. If a project company has purchased 20 acres in Shankarpally mandal, but one corner parcel or internal road access has a 22-A issue, a lender may not ignore it. If a plotted layout near Kadthal or Yacharam depends on a road passing through questionable land, that too can become a project finance concern.

Telangana 22-A Tags may change audit notes for developers

Audit notes usually focus on loans, receivables, related-party transactions, inventory valuation and statutory dues. Land title risks are often handled in legal reports, not always in the financial statements. That may change if financiers begin asking a direct question: does the developer’s land bank include any 22-A tagged property or land exposed to such claims?

For listed developers, large LLPs, private real estate groups and SPVs raising construction finance, auditors may start seeking written management representation on land status. In practical terms, the audit file may include:

• Survey-number-wise 22-A status for every project land parcel.
• Dharani and pahani copies for agricultural-origin land before conversion.
• SRO-wise registration history and mutation trail.
• Legal opinion on assigned land, government land or endowment land risk.
• Disclosure of any land parcel under litigation, stay order or registration refusal.
• Bank mortgage confirmation showing whether the secured land is fully marketable.

This is especially relevant in HMDA growth belts where agricultural land is converted for villas, plotted layouts and gated communities. The heat is visible around Gandipet mandal, Rajendranagar, Serilingampally, Patancheru, Shankarpally, Medchal, Ghatkesar, Maheshwaram and Shamshabad. These are not small village markets anymore. They are finance-heavy corridors where banks, NBFCs and private credit funds are active.

Why financiers may ask tougher questions

Project finance depends on mortgageable land, saleable inventory and predictable cash flows. A 22-A issue can disturb all three. If registration of a land parcel is blocked, the lender’s collateral value drops. If apartment buyers cannot get clean sale deeds, collections slow down. If the title dispute reaches RERA complaints or court, the project’s reputation takes a hit.

Telangana’s transaction cost also makes buyers more careful. For a standard sale deed, buyers typically factor in around 4% stamp duty, 1.5% transfer duty and 0.5% registration fee. On a ₹1 crore flat, that works out to roughly ₹6 lakh in statutory registration charges. Nobody wants to spend that kind of money and later discover a prohibited property issue. Buyers can estimate these costs through the Stamp Duty Calculator and compare declared values using the Market Value / Guideline Value Search.

Hyderabad developers may need cleaner land-room discipline

In our experience, the best-run developers already maintain what we call a “land room” — a structured folder of title deeds, link documents, ECs, pahani copies, mutation proceedings, conversion orders, layout permissions, RERA filings, mortgage releases and SRO records. The next step is to include a 22-A status note for every survey number.

This is not only for luxury projects in Kokapet or Financial District. It matters for villa projects near Mokila and Kollur, plotted layouts around Shadnagar, industrial-side land in Kandukur, warehousing pockets near Medchal, and budget apartment projects in Pocharam and Ghatkesar. As land prices rise, even a small title cloud can become a major funding issue.

Buyers should also not rely only on brochures. Check the project registration through RERA Project Lookup, identify the correct registration office through Find Your SRO Office, and track changes in land or ownership using the Property Change Tracker. If the project is still at land aggregation stage, the Property Verification Tool gives a useful starting point for risk screening.

Telangana 22-A Tags can hit buyer trust before legal closure

Real estate runs on trust much before the sale deed is registered. A rumour that one survey number is under 22-A can slow enquiries for the entire project, even if the issue affects only a small portion. Sales teams then spend weeks explaining legal documents instead of closing bookings. Channel partners become cautious. Banks may put disbursements on hold till their legal panel clears the land.

For developers, proactive disclosure is better than damage control. If a parcel had an old 22-A issue that was resolved, keep the government order, SRO clarification and legal opinion ready. If a neighbouring parcel is prohibited but the project land is clean, show the village map and survey sketch. If access road rights are private, record them properly. These small steps save large headaches.

For buyers, the practical rule is simple: do not stop at the apartment number. Ask for the underlying survey numbers. Ask which mandal and SRO the land falls under. Compare the RERA land schedule with EC, Dharani and approval documents. If the builder hesitates to share basic land details, treat that as a warning sign.

What may happen next in Telangana’s funding market

We expect three changes. First, lenders may add 22-A verification as a standard item in project appraisal. Second, auditors may ask for a management certificate confirming that project land is not under prohibited property categories. Third, serious developers may begin publishing cleaner title summaries in buyer packs, especially for premium projects.

This does not mean every 22-A reference will stop development. Some entries may be old, wrongly mapped or already resolved through official proceedings. But until the record is clarified, financiers will price the uncertainty. In real estate, uncertainty has a cost: higher interest, slower approvals, lower buyer confidence and tougher negotiations.

The 147,934 prohibited property count is a signal. Telangana’s property market is maturing, and the paper trail has to mature with it. Developers who treat land disclosure as a finance issue, not just a legal formality, will find it easier to raise money and sell with confidence.