NISM Series VI · Chapter 13: Investor Services

L1 · Foundation

Investor Services — SCORES, the IEPF and online dispute resolution

The SCORES complaint system and its 2024 rebuild with two levels of review and auto-escalation, the transfer of long-unclaimed shares to the IEPF Authority, and the SMART ODR platform with its three stages of pre-conciliation, conciliation and arbitration.

12 min read · Worth 2% of the paper · Written from pages 214–218 of the official NISM workbook · Updated 18 September 2026

Where this chapter sits

Chapter 13 carries 2% of the paper — the joint-lightest chapter, and the last one. It covers three separate investor-protection mechanisms, and almost every examinable point is a timeline or a list of exclusions.

The number to fix first is 21 calendar days. It appears in both SCORES and ODR.

13.1 SCORES

SEBI Complaints Redress System (SCORES) platform is a web based centralized system to capture investor complaints against listed companies and registered intermediaries and is available 24x7.

It was introduced on June 8, 2011 and has been facilitating redressal of investor grievances in a speedy manner.

Against listed companies and registered intermediaries — that scope matters, because complaints against unlisted/delisted companies are excluded.

SEBI encourages investors to lodge complaints through electronic mode in SCORES. However, complaints received from investors in physical form are also digitized by SEBI and uploaded in SCORES. Thereafter, follow-up actions of the complaint are done in electronic form only i.e. through SCORES.

The benefits: investors can easily access, retrieve and preserve the complaints lodged by them in electronic mode. Further, it enhances the turnaround time and speed of redressal of a complaint.

Where to get help: investors may contact the Investor Associations (IAs) recognized by SEBI for any assistance in filing complaints on SCORES. The lists of Investor Associations are available on SEBI website (www.sebi.gov.in). Investors may also seek assistance in filing complaints on SCORES from SEBI's toll free helpline number 1800 266 7575 or 1800 22 7575.

SCORES 2.0

SEBI launched the new version of the SEBI Complaint Redress System (SCORES 2.0) on April 01, 2024.

The new version of SCORES strengthens the investor complaint redressal mechanism in the securities market by making the process more efficient through auto-routing, auto-escalation, monitoring by the 'Designated Bodies' and by reducing the timelines.

The website URL for SCORES 2.0 from April 01, 2024, is https://scores.sebi.gov.in, and investors can lodge complaints only through new version of SCORES from that date. SCORES is an online system where investors can lodge their complaints through web URL and an App.

The four salient features:

The timelines for redressal of investor complaints across the securities market i.e. 21 calendar days from date of receipt of complaint and Monitoring of the timely redressal of the investors' complaints by the 'Designated Bodies'
There will be two levels of review: First review by the 'Designated Body'. If the investor is dissatisfied with the resolution provided by the concerned Market participant Second review will by SEBI if the investor is still dissatisfied after the first review
Introduction of auto-escalation of complaints to the next level in case of non-adherence to the prescribed timelines by the Market participant or the Designated Body as the case may be
Integration with KYC Registration Agency database for easy registration of the investor on to SCORES

Auto-escalation is the significant change. A complaint no longer stalls because nobody acted — missing a deadline pushes it up automatically.

How a complaint travels

Submission and handling:

Complaints lodged through SCORES are automatically forwarded to the concerned Entity with a copy marked to the Designated Body. Entities shall resolve the Complaint and upload the Action Taken Report (ATR) on SCORES within 21 calendar days of receipt of the Complaint. The ATR is automatically routed to the complainant.

SEBI may concurrently monitor the Entities and Designated Bodies grievance redressal process. The Designated Body shall monitor the ATRs submitted by the Entities.

First review:

If a complainant is satisfied with the resolution provided vide the ATR or does not file a review, the Complaint shall be disposed on SCORES. However, if not satisfied, the complainant may request a review within 15 calendar days from the date of the ATR.

If a complainant files a review, or the Entity has not submitted the ATR within 21 days, the Designated Body shall begin the first review with the Entity. The revised ATR shall be delivered by the Designated Body to the complainant via SCORES within 10 days from the review request.

SEBI shall handle the first review Complaint for intermediaries, where no Designated Body is appointed.

And on powers: this Circular permits Designated Bodies to monitor and handle grievance redressal and take non-enforcement actions and refer to SEBI the enforcement actions.

Second review:

Within 15 calendar days of the Designated Body submitting the ATR, complainant may request a second review, through SCORES. If a complainant is satisfied with the Designated Body's ATR or does not opt for review, within 15 days, the Complaint will be disposed of.

If the complainant is not satisfied with the Designated Body's ATR, or such ATR is not submitted within 10 days, SEBI may initiate review with the stakeholders, including the Entity and/or Designated Body. The Entity and/or Designated Body must submit a revised ATR to SEBI through SCORES, within the timeline specified.

And a point about when a second-review complaint is actually finished: SEBI or the Designated Body may seek the Entity's clarification on the ATR submitted for review. The second review Complaint shall be treated as 'resolved', 'disposed' or 'closed' only upon SEBI's disposal or closure of the Complaint in SCORES and not merely upon filing of the ATR for SEBI review.

Filing the report is not the same as closing the complaint.

The timeline in one place

Step	Time
Entity resolves and uploads ATR	21 calendar days of receipt
Complainant requests first review	Within 15 calendar days from the date of the ATR
Designated Body delivers revised ATR	Within 10 days from the review request
Complainant requests second review	Within 15 calendar days of the Designated Body's ATR
SEBI may initiate review	If the DB's ATR is not submitted within 10 days

General provisions

Investors must first address their concerns to the Entity's designated compliance and investor complaint officials. Then within 1 year from the date of occurrence, they may lodge a Complaint, by registering on SCORES and providing requisite PAN and contact details.

Two conditions before SCORES: approach the entity first, and file within 1 year from the date of occurrence.

What SCORES will not handle

Following Complaints are excluded from SCORES processing:

a. against unlisted/delisted companies, or companies on dissemination board of stock exchanges (except those related to securities valuation); b. tied to court cases or quasi-judicial matters, disputes within ODR managed by MIIs; c. falling within the jurisdiction of other regulatory bodies/ministries; d. against companies undergoing resolution under the insolvency and bankruptcy code; e. against companies removed from the register, or vanishing, or liquidated companies; or f. categorized as market intelligence, for violations of securities laws reported to SEBI.

Note (c) especially — a complaint that belongs to PFRDA, IRDAI or another regulator does not belong in SCORES.

And the alternative routes: the complainant may choose appropriate remedies through ODR or approach other legal forums (civil or consumer courts) if not satisfied with the SEBI review or the dispute is in the nature of a lis or the issues require third party rights adjudication.

But you cannot run both at once: if an alternative is chosen, while the Complaint is pending in SCORES, the Complaint will be deemed resolved.

CDSL's own facility

CDSL has developed a facility for investors to post complaints through CDSL website. A user-friendly format is made available on the website to enable the investors to register their complaints with ease.

The online complaint is automatically registered in CDSL Back office and same is being forwarded to respective DP to their web based audit login. The system driven alert for registration of complaints is also sent to DP on their registered email id.

CDSL has also developed a facility for upload/download Investor Grievance related correspondence through electronic mode i.e. through web based audit login. This facility has been made available to DPs/RTAs.

13.2 Transfer of shares to the IEPF Authority

In terms of Section 124(6) of Companies Act, 2013 and the Rules notified thereunder, the shares in respect of which dividend has not been paid or claimed for a period of seven consecutive years or more, are required to be transferred by the company to the Investor Education and Protection Fund Authority (IEPF).

Seven consecutive years of unpaid or unclaimed dividend. That is the trigger.

The transition date: as per the Rule 6 amended vide Investor Education and Protection Fund Authority (Accounting, Audit, Transfer and Refund) Amendment Rules, 2017, where the 7-year period provided under sub-section (5) of section 124 is completed during September 7, 2016 to May 31, 2017, the due date for transfer of such shares by companies was May 31, 2017.

How the transfer is made: all companies are required to transfer such shares to IEPF, whether held in dematerialized form or physical form, to the demat account of IEPF Authority by way of corporate action.

Physical or demat — everything goes into the IEPF Authority's demat account, by corporate action.

The three exceptions

In cases where there is a specific order of Court or Tribunal or Statutory Authority restraining any transfer of such shares and payment of dividend or where such shares are pledged or hypothecated under the provisions of the Depositories Act, 1996 or shares already been transferred under sub-rule (1) of above rules, the company shall not transfer such shares to the Fund.

A specific order of Court or Tribunal or Statutory Authority restraining transfer
Shares pledged or hypothecated under the Depositories Act, 1996
Shares already transferred

And the company must report the exceptions: the company is required to furnish a statement of shares not transferred to the Investor Education and Protection Fund (Form No. IEPF-3), which inter-alia requires the company to attach order of court/tribunal/statutory authority specifying the date of such order.

Form No. IEPF-3 is the statement of shares NOT transferred. It is easy to misremember this as the transfer form.

Getting the money back

A person whose amounts have been transferred to IEPF under the various clauses of sub sec (2) of section 205C after expiry of 7 years as per provisions of the Company Act, shall be entitled to get the refund out of the Fund in respect of such claims in accordance with rules made under this section.

Nothing is forfeited. The transfer to the IEPF is custodial, and the owner retains a right of refund.

13.3 Online Resolution of Disputes (ODR)

SEBI has put in place a common Online Dispute Resolution Portal ("ODR Portal") whereby the existing dispute resolution mechanism in the Indian securities market has been streamlined under the aegis of Market Infrastructure Institutions (MIIs), by expanding their scope and by establishing a common ODR Portal which harnesses online conciliation and online arbitration for resolution of disputes arising in the Indian Securities Market.

The authority: the same is as per SEBI (Alternative Dispute Resolution Mechanism) (Amendment) Regulations, 2023.

Who can be complained against. Under the ODR platform the investor/s can register the dispute against the following entities:

Listed Companies
Specified Intermediaries
Regulated entities

The portal: the separate portal https://smartodr.in is developed for registering the disputes on ODR platform. Investors needs to register on ODR platform.

The three stages

On SMART ODR, ODR comprises Pre-Conciliation, Conciliation, and Arbitration.

Pre-Conciliation: this is an initial stage where the Market Infrastructure Institution (MII) facilitates an amicable discussion between the investor and the intermediary/listed company/regulated entity (Market Participant). Resolving an issue in pre-conciliation ensures that formal proceedings are not initiated.

And the deadline: the market participant needs to resolve the dispute within 21 calendar days.

The same 21 calendar days as SCORES.

Conciliation: this is a more formal process where a conciliator (a neutral third party) works with the disputing parties to reach a mutually acceptable agreement. It's like a facilitated negotiation with the goal of finding a compromise that all parties can agree on.

Arbitration: this is a legal process where a dispute is resolved by one or more arbitrators (neutral third parties) whose decision (the arbitral award) is binding and enforceable.

Read the three in order and the escalation is clear. Pre-conciliation is a conversation. Conciliation is a facilitated negotiation, where the neutral works with the parties but does not decide. Arbitration is a determination — binding and enforceable.

The key distinction to hold: a conciliator helps the parties agree; an arbitrator decides for them.

And note the relationship with SCORES: complaints tied to court cases or quasi-judicial matters, disputes within ODR managed by MIIs are excluded from SCORES processing — the two systems do not run in parallel on the same dispute.

Think of it like this

SCORES 2.0 escalates by itself when a deadline passes

An old complaint register worked only if somebody remembered to chase it. A modern system escalates on the calendar, whether or not anybody remembers.

That is the central change in SCORES 2.0, launched on April 01, 2024: introduction of auto-escalation of complaints to the next level in case of non-adherence to the prescribed timelines by the Market participant or the Designated Body as the case may be.

The other three features: the timelines for redressal of investor complaints across the securities market i.e. 21 calendar days from date of receipt of complaint and Monitoring of the timely redressal of the investors' complaints by the 'Designated Bodies' · two levels of review: First review by the 'Designated Body'... Second review will by SEBI if the investor is still dissatisfied · and integration with KYC Registration Agency database for easy registration of the investor on to SCORES.

The clock runs in four steps. The Entities shall resolve the Complaint and upload the Action Taken Report (ATR) on SCORES within 21 calendar days. The complainant may request a review within 15 calendar days from the date of the ATR. The revised ATR shall be delivered by the Designated Body to the complainant via SCORES within 10 days from the review request. And a second review may be requested within 15 calendar days of the Designated Body submitting the ATR.

Missing any of them moves the file up rather than letting it sit. Indeed, if a complainant files a review, or the Entity has not submitted the ATR within 21 days, the Designated Body shall begin the first review — and if the complainant is not satisfied with the Designated Body's ATR, or such ATR is not submitted within 10 days, SEBI may initiate review.

One caution about what "done" means: the second review Complaint shall be treated as 'resolved', 'disposed' or 'closed' only upon SEBI's disposal or closure of the Complaint in SCORES and not merely upon filing of the ATR for SEBI review.

The IEPF is a lost-property office, not a confiscation

When a railway lost-property office takes in an unclaimed bag after a long enough wait, it does not become the railway's bag. It is held, catalogued, and returned if the owner turns up with proof.

That is exactly the design of the Investor Education and Protection Fund.

The shares in respect of which dividend has not been paid or claimed for a period of seven consecutive years or more, are required to be transferred by the company to the Investor Education and Protection Fund Authority (IEPF).

Seven consecutive years of unpaid or unclaimed dividend is the trigger — not seven years of silence generally.

Everything goes the same way: all companies are required to transfer such shares to IEPF, whether held in dematerialized form or physical form, to the demat account of IEPF Authority by way of corporate action. Physical certificates are dematerialised into the Authority's account.

But nothing is forfeited: a person whose amounts have been transferred to IEPF... after expiry of 7 years as per provisions of the Company Act, shall be entitled to get the refund out of the Fund in respect of such claims in accordance with rules made under this section.

Three categories of share stay put: where there is a specific order of Court or Tribunal or Statutory Authority restraining any transfer of such shares and payment of dividend, where such shares are pledged or hypothecated under the provisions of the Depositories Act, 1996, or where shares already been transferred.

A pledged share is somebody's security; a share under a court order is nobody's to move.

And the exceptions must be declared: the company is required to furnish a statement of shares not transferred to the Investor Education and Protection Fund (Form No. IEPF-3), which inter-alia requires the company to attach order of court/tribunal/statutory authority specifying the date of such order.

Note what IEPF-3 is — a statement of what was not transferred, and why.

A conciliator helps you agree; an arbitrator decides for you

When two neighbours quarrel, an elder who sits them down and helps them find a compromise is doing one thing. A magistrate who hears both and issues an order is doing something quite different. Both settle the dispute; only one of them decides it.

On SMART ODR, ODR comprises Pre-Conciliation, Conciliation, and Arbitration.

Pre-Conciliation: this is an initial stage where the Market Infrastructure Institution (MII) facilitates an amicable discussion between the investor and the intermediary/listed company/regulated entity (Market Participant). Resolving an issue in pre-conciliation ensures that formal proceedings are not initiated. The market participant needs to resolve the dispute within 21 calendar days.

Conciliation: this is a more formal process where a conciliator (a neutral third party) works with the disputing parties to reach a mutually acceptable agreement. It's like a facilitated negotiation with the goal of finding a compromise that all parties can agree on.

Arbitration: this is a legal process where a dispute is resolved by one or more arbitrators (neutral third parties) whose decision (the arbitral award) is binding and enforceable.

Both the conciliator and the arbitrator are neutral third parties — that is not the difference. The difference is in the verbs. The conciliator works with the disputing parties to reach a mutually acceptable agreement; the arbitrator resolves the dispute with an award that is binding and enforceable.

Where the platform came from: SEBI has put in place a common Online Dispute Resolution Portal... under the aegis of Market Infrastructure Institutions (MIIs), by expanding their scope and by establishing a common ODR Portal which harnesses online conciliation and online arbitration, as per SEBI (Alternative Dispute Resolution Mechanism) (Amendment) Regulations, 2023.

Three kinds of respondent: Listed Companies · Specified Intermediaries · Regulated entities. And the portal is https://smartodr.in.

You cannot fight the same battle in two places at once

A person who files a case in court and simultaneously asks the local grievance officer to decide the same matter is asking two authorities to reach possibly different answers on the same facts. Systems designed sensibly do not allow it.

SCORES therefore steps aside in several situations.

Following Complaints are excluded from SCORES processing:

Read them together and three principles emerge. SCORES covers listed companies and registered intermediaries, so unlisted, delisted, vanished and liquidated companies fall outside. It does not compete with courts, tribunals, the IBC process or the ODR platform. And it does not stray into the jurisdiction of other regulatory bodies/ministries — a pension grievance belongs to PFRDA, not SEBI.

The same principle governs what happens if an investor switches horses mid-race: the complainant may choose appropriate remedies through ODR or approach other legal forums (civil or consumer courts) if not satisfied with the SEBI review or the dispute is in the nature of a lis or the issues require third party rights adjudication. If an alternative is chosen, while the Complaint is pending in SCORES, the Complaint will be deemed resolved.

And before any of this, there is an even simpler rule: investors must first address their concerns to the Entity's designated compliance and investor complaint officials. SCORES is not the first stop — and once you do come, you must come within 1 year from the date of occurrence.

Two levels of review, and SEBI is the second one

A well-designed appeal system does not send every dispute to the top. It lets the body closest to the trade look first, and reserves the regulator for what remains unsettled.

There will be two levels of review: First review by the 'Designated Body'. If the investor is dissatisfied with the resolution provided by the concerned Market participant Second review will by SEBI if the investor is still dissatisfied after the first review.

Level zero is the entity itself. Complaints lodged through SCORES are automatically forwarded to the concerned Entity with a copy marked to the Designated Body. Entities shall resolve the Complaint and upload the Action Taken Report (ATR) on SCORES within 21 calendar days of receipt of the Complaint. The ATR is automatically routed to the complainant.

Level one is the Designated Body. It begins the first review either because a complainant files a review, or because the Entity has not submitted the ATR within 21 days — and must deliver its revised ATR... within 10 days from the review request.

Where there is no Designated Body, SEBI stands in: SEBI shall handle the first review Complaint for intermediaries, where no Designated Body is appointed.

Level two is SEBI proper, engaged where the complainant is not satisfied with the Designated Body's ATR, or such ATR is not submitted within 10 days.

The division of powers is neat: this Circular permits Designated Bodies to monitor and handle grievance redressal and take non-enforcement actions and refer to SEBI the enforcement actions. The Designated Body can fix things; only SEBI can punish.

And throughout, oversight runs both ways: SEBI may concurrently monitor the Entities and Designated Bodies grievance redressal process. The Designated Body shall monitor the ATRs submitted by the Entities.

Key terms in this chapter

Action Taken Report (ATR): The report an entity must resolve and upload on SCORES within 21 calendar days of receiving a complaint, automatically routed to the complainant.
Arbitration: The ODR stage in which one or more neutral arbitrators resolve the dispute by an arbitral award that is binding and enforceable.
Auto-escalation: The SCORES 2.0 feature by which a complaint moves to the next level automatically where the market participant or Designated Body fails to meet the prescribed timelines.
Conciliation: The ODR stage in which a neutral third party works with the disputing parties to reach a mutually acceptable agreement — a facilitated negotiation rather than a determination.
Designated Body: The body that conducts the first review of a SCORES complaint, monitors entities' ATRs, takes non-enforcement actions and refers enforcement actions to SEBI. Where none is appointed for an intermediary, SEBI conducts the first review.
Form No. IEPF-3: The statement of shares NOT transferred to the Investor Education and Protection Fund, to which the company must attach any court, tribunal or statutory authority order specifying its date.
IEPF Authority: The Investor Education and Protection Fund Authority, to whose demat account companies must transfer, by corporate action, shares whose dividend has been unpaid or unclaimed for seven consecutive years or more.
Lis: A contested claim between parties. Where a dispute is in the nature of a lis, or requires third party rights adjudication, the complainant may move to ODR or a civil or consumer court instead of SCORES.
ODR Portal: The common Online Dispute Resolution Portal at smartodr.in, established under the SEBI (Alternative Dispute Resolution Mechanism) (Amendment) Regulations, 2023, under the aegis of Market Infrastructure Institutions.
Pre-Conciliation: The first ODR stage, where the MII facilitates amicable discussion between investor and market participant so that formal proceedings are not initiated. The participant must resolve within 21 calendar days.
SCORES: SEBI Complaints Redress System — a web based centralized system available 24x7 to capture investor complaints against listed companies and registered intermediaries, introduced on June 8, 2011.
SCORES 2.0: The version launched on April 01, 2024 at scores.sebi.gov.in, adding auto-routing, auto-escalation, monitoring by Designated Bodies, reduced timelines and KRA database integration.
Section 124(6): The provision of the Companies Act, 2013 requiring transfer to the IEPF Authority of shares in respect of which dividend has not been paid or claimed for seven consecutive years or more.

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Original explanatory writing based on the official NISM workbook for Series VI, which is published and copyrighted by NISM. Check figures against the current edition at nism.ac.in.

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