SEBI Complaints Handling for Research Analysts (2026)
Every SEBI-registered Research Analyst has to run a grievance process: a way for clients to complain, fixed timelines to respond, and a record of what happened. Get it wrong and a single unresolved complaint becomes a SEBI inspection finding. Here is how complaint handling works for an RA in 2026, across SCORES 2.0 and the ODR portal, and the records that keep you clean.
Note: This is general information for Research Analysts, not legal advice, and SEBI timelines change. Confirm the current rules against the SEBI circulars and the SCORES and ODR portals before you rely on them.
The three places a complaint can land
A client unhappy with your service has three routes, and you have to be ready for all of them:
- Directly with you. The first and best place. Most complaints can be closed here if you respond quickly and keep a record.
- SCORES 2.0. SEBI's complaint redressal system at scores.sebi.gov.in, which routes the complaint to you and tracks the clock.
- The ODR portal. Online Dispute Resolution at smartodr.in, for disputes not resolved through SCORES or where the investor wants conciliation or arbitration.
SCORES 2.0 timelines
SCORES 2.0 tightened the process and put it on the clock. When an investor files a complaint, the system auto-routes it to you and starts a timer:
- 21 calendar days for you to resolve the complaint and post an Action Taken Report.
- First Level Review: if the investor is not satisfied, they have 15 days to escalate to the designated body that supervises you.
- Second Level Review: a further escalation, and then to SEBI, each within its own 15-day window.
The practical takeaway is simple: do not let a SCORES complaint sit. SEBI publishes resolution statistics, average resolution times are now measured in single-digit days, and a backlog is a visible red flag at inspection.
When a complaint moves to ODR
The Online Dispute Resolution portal is the common platform for resolving investor disputes with SEBI-regulated entities through conciliation and, if needed, online arbitration. A complaint that is not resolved through SCORES, or where the investor is unhappy with the outcome, can be taken to ODR. As an RA you are within scope: you must be registered to receive ODR references and you must display the ODR link in your grievance section. Treat an ODR reference seriously; it is a formal dispute, not a support ticket.
What you must display and publish
- Your grievance redressal mechanism and the contact for complaints, both in your office and on your website.
- Links to SCORES and the ODR portal.
- Your investor charter.
- A periodic complaints disclosure: complaints received, resolved and pending for the period.
- Your registered name and SEBI registration number, including on the social media handles you use to reach clients.
Keep a complaint register
Maintain a log of every complaint with the date received, who complained, the nature of the complaint, the action you took, the resolution date, and the channel (direct, SCORES or ODR). This sits alongside your Regulation 25 record-keeping and should be retained for five years. When your annual compliance audit comes around, the register is one of the first things the auditor asks for.
Most complaints are really record disputes
In practice a large share of RA complaints come down to a disagreement about what was communicated: a client says you never sent a risk disclosure, or that you made a call you did not. If your records are a WhatsApp history and a few screenshots, you are arguing from a weak position. If every note you sent is timestamped, hashed and exportable, you can show exactly what went out and when, and most disputes end there.
This is where Aktai helps before a complaint is ever filed: every research note you send is SHA-256 hashed and stored for five years, so the record that resolves the dispute already exists. The complaint workflow itself still runs through SCORES and ODR; Aktai gives you the evidence, not a replacement for the process.
FAQ
How long does a Research Analyst have to resolve a SCORES complaint?
Under SCORES 2.0, a complaint is auto-routed to the entity and you have 21 calendar days from receipt to resolve it and post an Action Taken Report. If the investor is not satisfied, they can seek a First Level Review within 15 days, then a Second Level Review with the designated body, and finally SEBI, each within its own window. Faster is better: SEBI tracks and publishes resolution times.
What is the ODR portal and does it apply to Research Analysts?
The Online Dispute Resolution (ODR) portal, smartodr.in, is a common platform for resolving disputes between investors and SEBI-regulated entities through conciliation and online arbitration. It applies to Research Analysts. A complaint not resolved through SCORES, or where the investor is unhappy with the outcome, can move to ODR. You must display the ODR link and your grievance process on your website.
Does a Research Analyst need a complaint register?
Yes. You must maintain records of complaints received and how they were handled. Keep a register or log with the complaint date, complainant, nature, action taken, resolution date and channel (direct, SCORES or ODR). These records sit alongside your Regulation 25 record-keeping and should be retained for 5 years.
What complaint disclosures must a Research Analyst publish?
Display your grievance redressal mechanism and contact in your office and on your website, link to SCORES and the ODR portal, and publish your investor charter and a periodic complaints disclosure (complaints received, resolved and pending). SEBI also requires regulated entities to display their registered name and registration number, including on social media.
How can software help with RA complaint handling?
The single biggest help is a clean, tamper-evident record of what you sent each client and when. When a complaint claims you never sent a disclosure or made a call you did not, a timestamped, hashed audit trail of your research notes settles it quickly. Aktai keeps that Regulation 25 audit trail automatically; the complaint workflow itself still runs through SCORES and ODR.