SMART ODR for SEBI Research Analysts: What Happens When a Client Escalates
Your investor charter tells every client where to go if they do not like your answer. Most RAs have never read what happens next.
Short answer: a client who is not satisfied with how you handled a complaint can file it on SEBI's SMART ODR platform. A conciliator tries to settle it in 21 days. If that fails, it can go to online arbitration with an award in 30 days. You pay the conciliation fees, and you cannot start arbitration yourself without depositing the amount the conciliator found payable.
Where it starts
The investor charter on your own website says:
If the Investor is not satisfied with the resolution provided by the Market Participants, then the Investor has the option to file the complaint/ grievance on SMARTODR platform for its resolution through online conciliation or arbitration.
The rules behind that line are in SEBI's Master Circular for Online Resolution of Disputes (SEBI/HO/OIAE/OIAE_IAD-1/P/CIR/2023/145), addressed to all SEBI registered intermediaries.
The five steps and their clocks
| Step | Clock | What happens |
|---|---|---|
| 1. Complaint to you | Up to 21 days | The client raises it with you first. The investor charter gives you 21 days to resolve it. |
| 2. SCORES (optional) | Per SCORES timelines | The client can escalate on SCORES, reviewed by RAASB and then SEBI. |
| 3. ODR conciliation | 21 days, plus up to 10 by consent | A sole independent conciliator is appointed within 5 days and holds one or more meetings to reach a settlement. |
| 4. Admissible claim value | At the end of failed conciliation | The conciliator sets the amount they find payable to the client. |
| 5. Online arbitration | Award within 30 days | Documents only for claims of ₹1 lakh or less. Above that, hearings, and the arbitrator can extend by up to 30 more days. |
The client does not have to go through SCORES first. They can move to ODR at any stage once your own answer has failed to satisfy them. The claim has to be within the law of limitation, counted from when the issue arose or the last disputed transaction.
The money
Registering a complaint on the portal costs the client nothing. Conciliation fees fall on you, and the circular says you may not shift them to the client at any time. A late fee applies when conciliation starts more than six months after the dispute arose.
If conciliation fails, the conciliator sets an admissible claim value. The client can then go to arbitration by paying the arbitration fee. If you want arbitration instead, you first deposit 100% of that value with the relevant market infrastructure institution and pay the fees. Refuse, and you cannot arbitrate, and the circular warns you can be declared not fit and proper, with your registration at risk.
Fees change: the circular sets the conciliation and arbitration fee amounts in a schedule that SEBI can revise. Check the current schedule on the SMART ODR portal before you budget.
How to be ready before a complaint arrives
A conciliator works from documents. The RA with a clean record of what was agreed, sent and said settles faster, and often never reaches arbitration.
- Answer every complaint in writing within 21 days, even when the answer is no
- Keep the client’s agreement, MITC and risk disclosures signed and dated
- Keep every research note and call you sent them, with the time it went out
- Keep call recordings and chat history: a conciliator weighs what was said
- Log each complaint, what you did and when, in your complaint register
- Budget for conciliation fees: they are yours, never the client’s
In Aktai, the complaint register runs the 21-day clock and generates the monthly Annexure E table, and every note and call you send is kept with the time it went out. The ODR process itself runs on the SMART ODR portal, not in Aktai. See the features page.
Questions RAs ask
Does SMART ODR apply to Research Analysts?
Yes. SEBI’s ODR master circular is addressed to all SEBI registered intermediaries, and the investor charter every RA displays tells clients they can take an unresolved complaint to the SMARTODR platform.
Can a client go to ODR without complaining to me first?
The client first raises the complaint with you. If your answer does not satisfy them, they can go to SCORES or straight to ODR, at any stage of the escalation. They do not have to finish SCORES first.
Who pays for conciliation?
You do. The circular puts the conciliation fees on the market participant and forbids passing them on to the client. Registering a complaint on the portal is free for the client.
Can I take a client to ODR?
Yes. A market participant can start the process after giving the client at least 15 calendar days’ notice to resolve the dispute.
What if I disagree with the conciliator and want arbitration?
You must first deposit 100% of the admissible claim value the conciliator set, and pay the arbitration fees. If you do not deposit, you cannot start arbitration, and you risk being found not fit and proper, with registration action to follow.
General guidance for SEBI-registered Research Analysts in India, not legal advice. Aktai is software; you, the registered RA, handle complaints and disputes. Based on the ODR master circular as read on 27 October 2026. Check the current circular before relying on any point here.