An unanswered or unsatisfactory response from a Registrar and Transfer Agent (RTA) does not mean that every investor should immediately start arbitration. The appropriate route depends on whether the issue is an incomplete service request, a grievance about handling, or a dispute that requires adjudication.
For investor service requests involving a listed company or its RTA, SEBI's January 2026 FAQs describe the broad sequence as: approach the listed company or RTA first; if the response is unsatisfactory, use SCORES; and if the matter remains a dispute, consider SMART ODR.
This guide explains how to build a clear evidence trail, protect the short review windows on SCORES and decide whether a grievance or dispute route fits the facts. Requirements should be rechecked on the official SCORES portal before filing.
First identify the actual problem
A service request and a grievance are related but not identical. A service request asks the company or RTA to process an action such as a KYC update, duplicate-security request, transmission or another folio change. A grievance says that the request has not been handled properly—for example, there is no response, the stated objection is unclear, or the investor believes the applicable documents have already been supplied.
- Incomplete request: correct the missing or mismatched item using the current issuer/RTA checklist before escalating.
- Handling grievance: complain to the listed company/RTA with the request reference, timeline and evidence.
- Substantive dispute: consider whether SMART ODR or another appropriate remedy is needed after first approaching the market participant.
Do not describe a request as “delayed” without recording when complete documents were received, what objections were raised and how you answered them. A focused chronology is more useful than a long narrative.
The escalation routes at a glance
SCORES and SMART ODR are not always compulsory consecutive stages. SEBI's RTA framework says that after an unsatisfactory response from the market participant, an investor may escalate on SCORES or may use SMART ODR. The correct choice depends on whether redressal facilitation or dispute resolution is required.
Step-by-step: build and escalate the complaint
- Confirm the correct entity. Verify the current listed company and issuer-appointed RTA. An old certificate or letter may show an outdated registrar.
- Separate the request from the complaint. Record what service was requested, when it was lodged, what was submitted and the exact unresolved point.
- Complain to the company/RTA. Use its dedicated grievance email or published channel. Include the issuer, folio, shareholder name, request reference, earlier correspondence and relevant documents.
- Save the complete record. Keep acknowledgements, courier proof, emails, objection letters, responses and a dated chronology.
- Use SCORES if redressal is unsatisfactory. Register with the required KYC information and upload a concise complaint with evidence. SCORES states that a complaint may generally be lodged within one year from the cause of action, subject to its rules.
- Read the Action Taken Report (ATR). Do not assume that submission of an ATR means the underlying issue has been solved.
- Use review on time. Current SCORES FAQs give the complainant 15 calendar days from the ATR to seek first-level review when dissatisfied, and another 15-calendar-day opportunity after the Designated Body's response to seek second-level review.
- Consider SMART ODR for a dispute. Review the applicable process, jurisdiction, evidence and cost structure before initiating pre-conciliation, conciliation or arbitration.
The current SCORES FAQs say the entity has 21 calendar days to upload its ATR. If it does not, the matter is automatically escalated to the next review level. Portal notices and case-specific directions should still be followed carefully.
Evidence checklist before you file
- Company name, folio number and shareholder name as recorded
- Investor service request number and date of complete submission
- Copy of forms, supporting documents and delivery acknowledgement
- Every objection, deficiency memo and point-by-point reply
- The outcome requested, stated in practical and specific terms
- A short chronology with filenames that match the dates and events
Mask unnecessary bank, identity and account details where the portal or recipient does not require them. Never upload altered documents or omit facts that materially affect the request.
When SCORES may not be the right forum
SCORES is for grievances against listed companies, SEBI-registered intermediaries and relevant market institutions. Its official FAQs list matters that are outside its scope. For Vitta Samadhan's audience, one especially important distinction is that claims for shares or dividends already transferred to IEPF fall under the IEPF Authority rather than SCORES.
The portal also does not decide questions requiring adjudication of competing rights or disputed facts. Such cases may need ODR, a court, tribunal or another authority depending on the issue. Forum selection should be based on the records, not on which portal appears quickest.
Frequently asked questions
Must I complete SCORES before using SMART ODR?
Not in every case. SEBI's current RTA grievance framework allows an investor who is dissatisfied after approaching the market participant to escalate on SCORES or use SMART ODR. SMART ODR itself requires that the matter first be taken up with the market participant.
What happens if I miss the 15-day SCORES review window?
The complaint may be disposed if review is not requested within the applicable window. Check the live complaint status and current portal FAQs immediately rather than relying on an old screenshot or email.
Can SCORES order the RTA to decide a disputed ownership claim?
SCORES facilitates grievance redressal and reviews responses; it does not adjudicate disputes between parties. A dispute involving third-party rights or contested facts may require ODR or another appropriate remedy.
Next step
Before escalating, reduce the case to a verified timeline: what was requested, what complete documents were delivered, what response was received, and what outcome remains unresolved. This makes it easier to choose between correction, grievance redressal and dispute resolution.
Need help reviewing an unresolved RTA matter?
Vitta Samadhan can help organise the request history, identify missing records and review the appropriate next-step documents for the facts of the case. Assistance does not guarantee acceptance, recovery or a particular outcome.
Visit Vitta Samadhan, call or WhatsApp 9312747174, or email support@vittasamadhan.com.
Disclaimer
This article provides general information as checked on 18 September 2026 and is not legal, investment or case-specific advice. Portal rules, timelines, jurisdiction and document requirements may change. Review the current official guidance and obtain appropriate professional advice for the facts of your case.