SEBI SCORES: The 21-Day Clock a Listed Company Cannot Miss
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An investor complaint on SCORES is not simply another item in the compliance inbox. Once a complaint is lodged against a listed entity, the entity has a defined period to resolve it and upload an Action Taken Report (ATR). Missing that window can trigger automatic escalation, while a weak ATR can invite a review even when it is filed on time.
For listed companies, the key is to keep three processes distinct: the SCORES complaint and review workflow, the separate Online Dispute Resolution (ODR) route, and the quarterly investor-grievance reporting obligation under SEBI LODR. They interact, but they are not the same compliance clock.
How a complaint reaches the listed entity
SCORES is SEBI's online grievance redressal platform for complaints relating to securities-market entities, including listed companies, registered intermediaries and market infrastructure institutions. A complaint lodged against an entity is forwarded through SCORES to the concerned entity for resolution and submission of its ATR. The relevant Designated Body is also notified and monitors the redressal process where applicable.
The practical point for a listed company is simple: the complaint should be treated as a tracked regulatory item from the moment it appears on the platform. Responsibility for redressal rests with the entity, while the designated compliance function should ensure that the matter is assigned, investigated, approved and uploaded within the prescribed timeline.
The 21-day Action Taken Report clock
The concerned entity must resolve the complaint and upload the ATR on SCORES within 21 calendar days of receipt of the complaint. These are calendar days, not working days, so weekends and holidays do not stop the clock.
The ATR should address the substance of the investor's grievance and explain the action taken. A response that merely repeats a general policy position may be technically uploaded but can still lead to dissatisfaction and review. A stronger ATR is factual and traceable: identify the issue raised, state the relevant records or transaction position, explain what the entity has done, and provide the outcome or next step where appropriate.
Where the issue belongs to another entity, the SCORES framework also provides a mechanism for seeking transfer through the concerned Designated Body, where available. The safer operational approach is not to leave such a complaint unattended while responsibility is being discussed internally; the entity should use the platform and the applicable process within the 21-day period.
What happens after the ATR?
| Stage | Who acts | Timeline |
|---|---|---|
| Entity response | Listed entity | ATR within 21 calendar days of receipt |
| First review | Complainant / Designated Body | Complainant may seek review within 15 calendar days of the ATR; Designated Body submits its response within 10 calendar days where the first review is taken up |
| Second review | Complainant / SEBI | Complainant may seek review within 15 calendar days of the first-review ATR; SEBI may take up the second review |
| ODR | Complainant, through ODR framework | Separate dispute-resolution route; not an automatic fourth SCORES stage |
If the entity does not submit the ATR within 21 calendar days, the complaint is treated as a failure to redress the grievance within the stipulated time and is automatically escalated to the first level review process. Similarly, where a complainant seeks review within the prescribed 15-day period, the matter can move into the next review stage.
A useful process distinction is that a complaint is not necessarily treated as finally disposed of merely because the entity has uploaded an ATR. The SCORES framework provides the complainant a 15-calendar-day period to seek review. The platform therefore uses an "Awaiting Review" stage after an ATR in the relevant circumstances.
Where ODR fits - and where it does not
Online Dispute Resolution is a separate mechanism in the Indian securities market. A complainant may opt for ODR or other appropriate civil remedies, and where the complainant opts for ODR while the matter is pending on SCORES, the complaint is treated as disposed of on SCORES in accordance with SEBI's framework.
That distinction matters operationally. SCORES is a regulatory grievance-redressal platform with its own response and review timelines. ODR is a separate dispute-resolution framework that may become relevant where the nature of the dispute and the parties make that route appropriate.
Regulation 13(3): a separate quarterly reporting obligation
Under the current listed-company framework, Regulation 13(3) forms part of Integrated Filing - Governance, which is to be submitted within 30 days from the end of the relevant quarter.
The quarterly statement covers the entity's investor-grievance position, including complaints received, disposed of and remaining pending, as prescribed. This reporting obligation therefore runs on a different clock from an individual SCORES complaint. A company can be within the 21-day ATR deadline for an individual complaint and still have a separate quarterly reporting or reconciliation issue.
The cleanest control is to reconcile the investor-grievance population before the quarterly Integrated Filing - Governance is submitted. The internal register, RTA records where relevant, SCORES records and the figures used for the quarterly statement should be capable of being traced to one another.
What a SCORES process that survives review looks like
- Set an internal target materially earlier than day 21 - for example, an internal drafting or escalation deadline around day 10 - so review and approval time is not consumed by the regulatory outer limit.
- Name a primary owner and a backup with appropriate access to SCORES. The entity remains responsible even when the underlying records or operational work sit with an RTA or another service provider.
- Build a standard ATR workflow: capture the complaint, identify the issue, obtain source records, draft the response, obtain the required approval, upload the ATR and retain the supporting trail.
- Reconcile SCORES and internal investor-grievance records before the quarterly Integrated Filing - Governance, rather than reconstructing the figures at quarter-end.
- Keep the current SEBI circulars, SCORES FAQs and applicable LODR reporting requirements in the compliance knowledge base and re-check them periodically for regulatory changes.
The answer, in one line
For a listed entity, the SCORES complaint clock is 21 calendar days from receipt for resolution and submission of the ATR; the complainant then has a 15-calendar-day review window, with first-level review by the relevant Designated Body and a possible second-level review by SEBI. ODR is a separate dispute-resolution route, while the quarterly investor-grievance statement under Regulation 13(3) runs through Integrated Filing - Governance on a 30-day quarter-end timeline.
One practical control is worth implementing immediately: take the current SCORES complaint list, map each item to its internal owner and due date, and reconcile the population against the investor-grievance register before the next Integrated Filing - Governance. A discrepancy found internally is much easier to fix than one identified after filing.
Reference links
- SEBI SCORES portal and current FAQs: SEBI SCORES - Current FAQs
- SEBI Circular dated 20 September 2023 - Redressal of investor grievances through SCORES and linking it to ODR: SEBI Circular - SCORES and ODR (20 September 2023)
- SEBI Master Circular for Online Resolution of Disputes in the Indian Securities Market: SEBI Master Circular - Online Resolution of Disputes
- NSE Compliance Calendar - Main Board (current listed-company timelines): NSE Compliance Calendar - Main Board
Frequently Asked Questions
Can a listed company simply reject a complaint on SCORES?
The safer approach is to respond through the platform rather than treat a complaint as rejected. If the company believes the grievance is misconceived, outside its remit, or otherwise cannot be redressed as requested, the ATR should explain the position with supporting facts. Where the matter pertains to another entity, the applicable SCORES process for transfer or referral should be used where available.
Who is responsible for a SCORES complaint - the company or the registrar?
The redressal obligation sits with the concerned entity. An RTA or other service provider may support the company with records or drafting, but the company should maintain ownership of the regulatory workflow, approvals and timely submission on SCORES.
Does a complaint filed directly with the company have to be uploaded on SCORES?
A complaint received directly by the company is not, merely because it is received internally, a SCORES complaint. It should be handled through the company's investor-grievance process. However, the company's broader investor-grievance records matter for the periodic statement under Regulation 13(3), so the internal register should be complete and capable of reconciliation with the data reported.
What happens if the investor does not request a review within 15 days?
Under the SCORES workflow, the complaint can be disposed of where the complainant does not choose to review the resolution within the applicable 15-calendar-day period. That does not make a weak ATR a good compliance strategy: the quality of the response should still be sufficient to substantively address the grievance.
Does the 21-day SCORES window pause for holidays?
No. The prescribed entity timeline is 21 calendar days, so weekends and holidays do not stop the clock.
Is Regulation 13(3) also a 21-day filing?
No. Do not confuse the individual SCORES ATR deadline with the quarterly investor-grievance statement. Regulation 13(3) is now part of Integrated Filing - Governance, which is due within 30 days from the end of the quarter under the current listed-company framework.
