Action Taken Report
Also written ATR · Action Taken Report (ATR)
The reply an entity must upload on SCORES saying what it did about an investor complaint — it is routed straight to the complainant and starts the clock on their right to ask for a review.
In plain language
A complaint on SCORES is not a letter into a void. It is forwarded automatically to the entity complained against, and the entity has to come back on the record with what it actually did.
That reply is the Action Taken Report. It is uploaded to SCORES, not posted to the investor, and the system routes it to the complainant on its own.
Everything that follows — first review, second review, escalation to SEBI — is measured from the date of that report. The ATR is therefore both an answer and a starting gun.
How it works
The framework is SEBI circular SEBI/HO/OIAE/IGRD/CIR/P/2023/156 dated 20 September 2023, which revised SCORES and linked it to the Online Dispute Resolution platform. The clock runs like this:
| Stage | Who acts | Time allowed |
|---|---|---|
| Resolve the complaint and upload the ATR | The entity | 21 calendar days of receipt of the complaint |
| Request a first review | The complainant | 15 calendar days from the date of the ATR |
| Submit the revised ATR on first review | The Designated Body | 10 calendar days of the review being sought |
| Request a second review | The complainant | 15 calendar days from the Designated Body's ATR |
| Second review | SEBI | SEBI takes cognizance |
For a stock broker, the Designated Body is the stock exchange, and it is the Designated Body's job to ensure the entity submits its ATR within the 21 days. On a first review the Designated Body may seek clarification from the entity, and must stipulate a timeline tight enough to let it file the revised ATR within its own 10 calendar days.
Two disposal rules complete the picture. If the complainant is satisfied with the Designated Body's ATR, or does not seek a second review within 15 calendar days, the complaint is disposed on SCORES. And a second-review complaint is treated as resolved, disposed or closed only when SEBI itself disposes or closes it — merely filing an ATR against a SEBI review complaint does not dispose of it.
A worked example
An investor's broker fails to credit a Rs 2.4 lakh pay-out. She complains to the broker's compliance officer first, as she must — taking the grievance up with the entity directly is mandatory before SCORES. Nothing happens. She lodges on SCORES on 1 September.
1 Sep Complaint lodged on SCORES, auto-forwarded to the broker
Email acknowledgement generated for tracking
22 Sep Last day for the broker to resolve and upload the ATR
(21 calendar days). ATR filed: "funds released".
Routed automatically to the complainant.
7 Oct Last day to seek a FIRST review (15 calendar days
from the ATR). She does: only Rs 1.9 lakh arrived.
17 Oct Last day for the stock exchange, as Designated Body,
to submit the revised ATR (10 calendar days).
1 Nov Last day to seek a SECOND review (15 calendar days).
SEBI may then take cognizance through SCORES.
And the limitation that decides whether she can start at all: a complaint may be lodged on SCORES within one year from the date of the cause of action, while the limitation period for filing an arbitration reference with a stock exchange is three years.
Why NISM asks about it
Chapter 7 (Investor Grievances and Arbitration, section 7.2.2.1) sets out SCORES and the ATR chain, and the chapter is generous with numbers, which means the paper is too. The four-number sequence 21 - 15 - 10 - 15 is the single most examinable string in the chapter. Series VII is marked at 50 per cent to pass with 25 per cent negative marking, so a guess between 15 and 21 days on a review window is not a free shot — if the sequence is not solid, the honest move is to leave the question blank.
Common exam traps
- 21 / 15 / 10 / 15, all calendar days. Entity 21 to file the ATR, complainant 15 to seek first review, Designated Body 10 for the revised ATR, complainant 15 for second review.
- The Designated Body for a stock broker is the stock exchange, not SEBI and not the depository.
- Silence disposes the complaint. If the complainant does not seek a second review within 15 calendar days, it is disposed on SCORES — inaction counts as acceptance.
- A SEBI review complaint is not disposed by filing an ATR. Only SEBI disposing or closing it ends it. This distinction is stated explicitly in the workbook and is a natural question.
- Approach the entity first. It is mandatory to take the grievance up with the entity's designated official before lodging on SCORES.
- One year for SCORES, three years for arbitration. Two different limitation periods for two different forums; do not carry one over to the other.
- The ATR uploaded on SCORES for a KRA's annual systems audit — sent to SEBI within 3 months — is a different report with the same name. Read which one the question is about.
Where this is taught
- Series IV · Chapter 10: Code of Conduct and Investor Protection Measuresintroduced here
- Series X-A · Chapter 20: Grievance Redress Mechanismintroduced here
- Series VI · Chapter 13: Investor Servicesintroduced here
- Series SEBI-ICE · Chapter 12: Grievance Redressal Mechanismintroduced here
- Series XIX-E · Chapter 11: Governance of Funds and Due Diligenceintroduced here
- Series VII · Chapter 7: Investor Grievances and Arbitrationintroduced here
- Series VIII · Chapter 10: Sales Practices and Investor Protection Measuresintroduced here
Related terms
- Investor CharterSEBI's published statement of what an investor is entitled to from an intermediary — the services, the rights, the dos and don'ts, and a table of activities with the timeline each one must be completed in.
- SCORESSEBI's centralised web-based system for processing investor complaints, on which the company or intermediary must upload an Action Taken Report and the investor can watch the status online.
- ArbitrationQuasi-judicial dispute resolution under the Arbitration and Conciliation Act, 1996, run online by an ODR Institution once conciliation fails; the award binds unless challenged under Section 34.
- Designated BodyUnder SEBI's revised SCORES framework, the body that monitors a regulated entity's complaint redressal and conducts the first review; for stock brokers it is the stock exchange.
- ODR InstitutionAn independent institution empanelled by a market infrastructure institution to conduct time-bound online conciliation and arbitration of securities market disputes on the SMART ODR portal.
- Online Dispute ResolutionThe MII-administered process — pre-conciliation, conciliation, then arbitration — through which investor disputes with portfolio managers are resolved online via the SMART ODR portal.
- SCORES 2.0The version of SEBI's online complaint redress system launched on 1 April 2024, which auto-routes complaints, gives the entity 21 calendar days to file an Action Taken Report, and auto-escalates when it does not.
- Auto-escalationA SCORES 2.0 feature that automatically pushes an investor complaint to the next review level when a market participant or Designated Body misses the prescribed redressal timeline.
- Investors Grievance DivisionThe department of a stock exchange that investors approach to resolve complaints against its trading members, working with the member and the complainant before any escalation to SEBI SCORES.