SEBI SCORES Complaints: A Research Analyst's Guide to Handling Them

Handling SEBI SCORES complaints as a Research Analyst

A complaint is the most visible test of a Research Analyst's practice. How fast you respond, what your records show and whether you disclose your complaint numbers honestly all count with clients, with RAASB and with SEBI. This guide covers the escalation path, the timelines, how to handle a complaint step by step, the monthly complaint data you must publish, and how to prevent complaints in the first place. The rules come from SEBI's Master Circular for Research Analysts dated 6 February 2026, including the Investor Charter in its Annexure D.

The complaint path, from RA to SMART ODR

You must also display the grievance information prominently in your office: your compliance officer's name, email and phone, the CEO, partner or proprietor's contact, and the SCORES route and SEBI helpline. Your investor charter and MITC tell clients the same path, so keep all three consistent.

Timelines you need to meet

• 21 days. The Investor Charter says the RA shall strive to redress a grievance immediately, but not later than 21 days from receipt.
• 7 business working days for service grievances raised with your designated person. The standard terms in Annexure B cover grievances about not receiving a research report, missing pages, being unable to download a report or any other service deficiency. They say the RA is responsible for resolving these within 7 business working days, or within any timeline SEBI specifies.
• Monthly disclosure by the 7th. Whatever happened in the month goes into the complaint data you publish by the 7th of the next month.

In practice, aim to acknowledge every complaint the same day and close service issues within a week. That keeps you well inside both limits.

How to handle a complaint, step by step

1. Acknowledge. Reply quickly in writing so the client knows it is being looked at. Log it in your complaint register the same day.
2. Gather the record. Pull the client's KYC, signed terms and MITC, payment and invoice, the research reports and messages they received, and your records of interactions. The regulations require you to keep these for five years.
3. Assess it honestly. Is it a service failure (report not delivered, wrong message, refund not paid), a misunderstanding of what the service is, or a complaint about losses? Losses on recommendations are a market risk the client accepted in the standard terms, but check that your disclosures and communications were sound.
4. Talk to the client. Call, then confirm in writing. Many complaints close once the client has been heard and the facts are explained.
5. Resolve and respond on SCORES. If the complaint is on SCORES, upload your response with the supporting documents. Address each point. If you are refunding, say how much and when.
6. Close the loop. Confirm with the client, update the register and fix the cause, whether that is a process, a template or a broken delivery channel.

Common complaint types and how to prevent them

Keep a complaint register

A complaint register is the simplest way to meet your record-keeping duty, run your 21-day clock and produce the monthly data. Make an entry for every complaint, whatever the channel.

Monthly complaint data: the Annexure E format

Every RA must publish, on its website and mobile app (if any), data on complaints received and their redressal, by the 7th of the following month. The format is in Annexure E of the master circular. It has two tables.

Table 1: data for the month

Rows for complaints received directly from investors, from SEBI (SCORES) and from other sources, plus a grand total. Columns:

• Pending at the end of last month
• Received during the month
• Resolved during the month, including complaints from earlier months
• Total pending at the end of the month
• Pending for more than three months
• Average resolution time in days: total days taken to resolve each complaint resolved this month, divided by the number resolved

Below it, state the number of complaints received during the month because of impersonation of the RA by another entity. You may adjust these out of the received and resolved totals, but you must still close them by due process.

Table 2: trend of monthly disposal

One row per month of the financial year from April to March, with complaints carried forward from the previous month, received, resolved and pending, and a grand total.

Publish a table every month, including months with no complaints. A full worked template is in our guide to the RA monthly complaint data format, and the deadline sits alongside the others in the SEBI RA compliance calendar.

SMART ODR

If a complaint is not resolved to the investor's satisfaction, the investor can use SEBI's online dispute resolution framework through the SMART ODR portal. The matter goes first to online conciliation and, if that fails, to online arbitration with an ODR institution. Take part in good faith, bring your records, and treat an adverse outcome as something to fix in your process. The framework is in SEBI's master circular on online resolution of disputes, referenced in the RA master circular.

How an investor can complain against a SEBI RA

If you are an investor: first write to the RA's compliance officer or grievance contact (shown on its website, terms and investor charter). If you are not satisfied, file on SCORES at scores.sebi.gov.in or email RAASB. If that does not settle it, use SMART ODR. You can also call SEBI's toll-free helpline on 1800 22 7575 or 1800 266 7575. Before subscribing to anyone, check that the research analyst is registered.

Complaints and your compliance record

RA registration does not expire, so there is no renewal review. But complaints still matter. Your monthly data is public. The annual compliance audit checks grievance handling. RAASB reviews SCORES complaints and may be assigned to inspect RAs on SEBI's behalf. A pattern of unresolved or repeated complaints is the kind of thing that draws attention.

AlphaQuark helps on the prevention side: KYC and MITC e-sign before payment, plan-linked access that ends when the paid period ends, alerts sent to every subscriber from one place, and dated records of every recommendation and message. See the RA platform.