Guide
How to Verify an SBCA NOC for Sale and Advertisement Before You Book
By Maham Imtiaz
Real Estate AnalystVerified author
11 min read
Almost every off-plan flat, shop and private-scheme plot in Karachi is sold with the same promise: "SBCA approved". The document that actually gives a builder the right to sell is narrower and more specific. It is the SBCA No Objection Certificate (NOC) for sale and advertisement, and without it, a builder has no legal right to take your booking money.
Karachi has several regulators, and our guide on how to verify property in Karachi explains which one controls the land, the building and the title for any property. For an off-plan unit outside DHA and the cantonments, the sale NOC is the first building check a buyer should make, because it decides whether the sale itself is legal.
This guide explains what the sale NOC is, what a real one contains, the conditions builders must follow under it, and a step-by-step method to verify it before you pay a single rupee.
What the SBCA sale NOC is
The Sindh Building Control Ordinance 1979 sets two rules that create the sale NOC:
| Section | What it says | Applies to |
|---|---|---|
| 5(1) | A developer cannot sell plots, or advertise them, without SBCA's NOC | Private housing schemes selling plots |
| 12(1) | A builder cannot sell or advertise a building without SBCA's written approval, and must mention it in the advert | Flats, shops and offices sold off-plan |
| 12(2) | The approval must be displayed at the builder's office and the site | Every approved project |
| 12(3) | A builder cannot register more applications than the building has units | Every approved project |
The sale NOC is separate from the approved building plan. A plan says a building may be built. The sale NOC says its units may be sold, on terms SBCA has approved. A project can have the first without the second, and a builder selling on a plan alone is still breaking the law.
It does not apply inside DHA or the six cantonment boards, where DHA or the board approves projects instead.
What a real SBCA sale NOC contains
Public filings show exactly what these NOCs look like. The SBCA sale NOCs for Naya Nazimabad Apartment-3 and Apartment-4, issued in January 2020, are a useful model because they set out every field a buyer should expect to see.
| Field | What the Naya Nazimabad NOCs show | Why it matters |
|---|---|---|
| Reference number and date | SBCA/DD-I(D&C-I) reference, January 2020 | Lets you confirm the NOC with SBCA |
| Builder and licence | Javedan Corporation, licence BL-3248 | Matches the seller to SBCA's licence record |
| Plot details | Plot FL-03, Survey Nos. 38 and 40, Scheme-43, Deh Manghopir | Matches the NOC to the exact land |
| Building structure | Two basements, ground and 13 residential floors | Shows how many floors may be sold |
| Unit schedule | Each unit type with floors, count, size and price | Fixes the number and price of units |
| Extra charges | Documentation, 2% transfer fee, 2% corner, 2% west open, 1% road facing | Caps what the builder can add |
| Completion date | 1 February 2024 for Apartment-3 | The delivery date promised to SBCA |
| Security | ABAD guarantee in lieu of a 1% security deposit | Shows the builder's security with SBCA |
| Conditions | 13 numbered conditions | Rules the builder must follow after booking |
| Signed by and copied to | Deputy Director, Design and Complaint; copies to vigilance and the district office | Shows which SBCA office issued and tracks it |
The NOCs also state that no addition or alteration is allowed in the approved documents at any stage. Any change to floors, units, prices or charges needs SBCA's fresh approval.
The conditions builders must follow
The conditions inside a sale NOC are where most buyer protection lies. The Naya Nazimabad NOCs include several that every buyer should look for:
- Booking cap before construction permit. Under an SBCA notification of 27 November 2019, the builder may advertise and take bookings but collect only up to 10% of the approved price until a valid construction permit is issued.
- Approved payment schedule. Later instalments must follow the schedule SBCA has approved.
- Registered agreements. Each buyer's agreement must be on stamp paper in the model format, signed within 30 days of booking and countersigned by ABAD within 15 days. Without it, the builder cannot collect further instalments.
- Notice board. A 4-by-4-foot board at the booking office must display the NOC, the building plan, the covered area and the unit numbers.
- Quarterly reports. The builder must report booked units and site progress to SBCA every quarter, verified by the licensed architect.
- Withdrawal for misrepresentation. Any misrepresentation of facts automatically withdraws the NOC, and violations can lead to suspension.
Not every NOC carries identical conditions, but these show what to ask about. If a builder is asking for 30% down payment before a construction permit, or refuses to sign a stamped agreement, the project is already outside the terms an SBCA NOC normally sets.
Step-by-step: how to verify an SBCA sale NOC
- Ask for the NOC by name. Request the "SBCA NOC for sale and advertisement", not "SBCA approval", and get its reference number and date.
- Check the notice board. Under section 12(2), the approval must be displayed at the booking office and on site. Photograph it.
- Match the builder. Confirm the builder's name and licence number on the NOC match the company taking your money.
- Match the land. Check the plot number, survey number, deh or scheme against the seller's title papers.
- Match the unit. Confirm your floor and unit type appear in the NOC's schedule, at the approved size and price.
- Check the charges. Compare every extra charge in the booking form with those listed in the NOC.
- Check the dates. Note the completion date and whether it has passed or been extended by SBCA.
- Check the construction permit. If the builder wants more than the booking cap, ask for the construction permit.
- Verify with SBCA directly. Confirm the NOC's status with SBCA's design and complaint section or official channels, never only through the builder.
- Check public warnings. Make sure the project is not named in any SBCA public notice about projects selling without NOCs.
Never accept a photocopy, a WhatsApp image or a brochure line as proof. Only SBCA can confirm that an NOC is genuine and current.
Why a past check is not enough
An NOC is a status, not a permanent right. Under section 6(5) of the Ordinance, SBCA can suspend or cancel approval before a building is completed, and NOCs can be withdrawn for misrepresentation or violations.
Bahria Town Karachi shows how quickly status can change. SBCA issued a provisional sale NOC for the 16,896-acre project on 19 September 2022, cancelled it on 23 October 2023 over unpaid scrutiny fees, and restored it in October 2024 on fresh conditions. A buyer who checked in 2022 and paid in late 2023 would have paid while the NOC stood cancelled.
Check the NOC's status again on the day you pay, and again before each large instalment.
Marketing claims are also under closer scrutiny. The Competition Commission of Pakistan has examined misleading real estate advertising, and our report on the CCP hearing on NOC claims and hidden charges covers how regulators are treating projects that overstate their approvals.
What happens if there is no NOC
Buying without a valid sale NOC is not just risky. Sindh's courts have said it can leave you with nothing.
In a 2023 order in CP No. 3725 of 2023, the Sindh High Court held that buyers of units in a building raised without an approved plan had no right, title or interest in their units and no right to a registered deed, even though they said they had been deceived. The court treated their agreements as void under section 23 of the Contract Act 1872.
Section 18-G of the Ordinance adds that no new unit can be registered or connected to utilities without SBCA's approved completion plan. A project that skipped the sale NOC is unlikely to reach a clean completion plan either.
NOC red flags
| What you hear or see | What it may mean |
|---|---|
| "SBCA approved" with no NOC reference | Plan approved at most, no sale NOC |
| "NOC applied" or "in process" | No approval yet; selling is unlawful |
| "Provisional NOC" | Conditional approval that can be withdrawn |
| More floors on sale than the NOC shows | Extra floors are unapproved |
| No notice board at the booking office | Breach of section 12(2) and usual NOC conditions |
| Large down payment before construction permit | Outside the usual booking cap |
| Different builder name on receipts | You may be paying someone outside the NOC |
| Completion date long past, no extension | Project delayed beyond its approved terms |
What the numbers show: Milkiyat.com findings
The booking cap protects most of your money. In Naya Nazimabad Apartment-3, a Type B unit was priced at Rs13.6 million. Under the 10% cap: Rs13,600,000 × 10% = Rs1.36 million could be collected before a construction permit, leaving Rs12.24 million that should wait for the permit.
One NOC fixed 138 units in a single building. Apartment-3's NOC listed 34 Type A units and 104 Type B units: 34 + 104 = 138 units. Under section 12(3), the builder could not register a 139th application. Documented approvals like these also add value later: the same project's apartments went on to back the Naya Nazimabad apartments REIT approved for PSX listing, something an unapproved building could never do.
A NOC's completion date is also a deadline. Apartment-3's NOC set completion for 1 February 2024, and Apartment-4's for 1 February 2025, a year later. Under section 13 of the Ordinance, a builder that misses its completion date without an SBCA extension owes interest to buyers on their payments.
Frequently asked questions
Q1. What is an SBCA NOC for sale and advertisement?
A. It is SBCA's written permission for a builder or developer to advertise and sell units or plots in a named project, on approved terms, prices and dates.
Q2. Is a building plan approval the same as a sale NOC?
A. No. A plan approval allows construction. The sale NOC allows units to be sold. A builder needs both before taking bookings.
Q3. How do I check if an SBCA NOC is genuine?
A. Get its reference number and date, match the builder, land and unit details, and confirm its status directly with SBCA, not through the builder.
Q4. How much can a builder collect at booking?
A. In NOCs issued under SBCA's November 2019 notification, builders could collect only up to 10% of the approved price before a construction permit was issued.
Q5. Can an SBCA NOC be cancelled?
A. Yes. SBCA can suspend or cancel it for violations, misrepresentation or unpaid fees, as happened with Bahria Town Karachi's provisional NOC in 2023.
Q6. Do I need an SBCA NOC in DHA Karachi?
A. No. Inside DHA and the cantonments, DHA or the relevant cantonment board approves projects instead of SBCA.
Q7. What if I already paid for a unit without an NOC?
A. Stop further payments, get legal advice and ask SBCA about the project's status. Courts have held that buyers in buildings without approvals may have no enforceable title.
This guide is for general information. NOC conditions and procedures change, and buyers should confirm every NOC, plan and permit directly with SBCA and a qualified lawyer before paying.