How to File a Complaint Against an Investment Adviser — A Complete Guide for Clients
Most investors instinctively want to go straight to the regulator when something goes wrong with an Investment Adviser. SEBI's actual grievance framework is built around a specific sequence — and skipping the first step can genuinely slow down, rather than speed up, resolution.
Step One — Raise It With the IA Directly
Every SEBI-registered IA is required to maintain a designated grievance-handling contact, and SEBI's own framework expects investors to first raise the issue directly with the IA in writing — typically by email — before escalating externally. A well-run IA practice will acknowledge the complaint promptly and respond within a defined internal timeline, generally expected to be within 10 business days.
Step Two — If There's No Response, or You're Not Satisfied
If the IA doesn't respond within a reasonable window, or responds in a way that doesn't actually resolve the issue, the next step is SCORES — the SEBI Complaints Redress System, accessible at scores.sebi.gov.in or through SEBI's mobile app. Once a complaint is lodged, it is automatically routed to the concerned IA, who is required to submit an Action Taken Report (ATR) within 21 calendar days under the current SCORES 2.0 framework.
What Happens If You're Still Not Satisfied After the ATR
If the ATR doesn't resolve the matter to your satisfaction, you can request a first-level review within 15 days, which is examined by a designated reviewing body that issues its own ATR. If that still doesn't resolve things, a second-level review can be sought within a further 15 days, after which SEBI itself examines the complaint directly and issues its own response.
The One-Year Window You Need to Be Aware Of
A detail that catches many investors off guard: a complaint must generally be lodged on SCORES within one year from the date the cause of action arose. Complaints filed after this limitation period may simply be rejected on that basis alone, regardless of the underlying merit — so don't sit on a grievance indefinitely before raising it formally.
The ODR Route — An Alternative to the SCORES Escalation Ladder
Rather than working through SCORES' review stages, an investor can instead opt for the Online Dispute Resolution (ODR) mechanism, established under a SEBI circular dated 31 July 2023, which offers conciliation and online arbitration specifically for securities market disputes. Choosing ODR is treated as an alternative path — a complaint is generally considered disposed of on SCORES once an investor opts to pursue it through ODR instead. Our companion article covers exactly how the ODR process itself works, step by step.
What Kind of Complaints Actually Belong Here
SCORES and ODR are built for grievances against SEBI-regulated entities specifically — deficiency of service, unresponsiveness, disputes over fees charged, documentation issues, or conduct inconsistent with the IA's regulatory obligations. Matters already pending before a court or in quasi-judicial proceedings, or genuine market-intelligence tips about a securities law violation (which have a separate reporting channel), are treated differently and generally fall outside SCORES' own scope.
What to Have Ready Before You File
A complaint moves faster, and is harder for the IA to dispute on procedural grounds, when it's filed with the advisory agreement, any written correspondence with the IA, fee payment records, and a clear, dated account of what happened — rather than a general grievance without supporting documentation.
Why This Matters as Much to IAs as to the Investors Raising Complaints
Every stage of this process places a specific, time-bound obligation on the IA itself — acknowledging complaints, responding within the internal window, and submitting a compliant ATR within the SCORES 2.0 deadline. An IA practice without a properly documented, tested grievance-handling process is exposed the moment a complaint actually lands, regardless of whether the underlying grievance has real merit.
How We Help
If you're an Investment Adviser, we help build and stress-test the grievance redressal process this framework requires — designated contact points, response-time tracking against the 21/15/15-day SCORES 2.0 clock, ATR drafting support, and Investor Charter compliance — so a complaint, when it lands, is handled correctly and on time rather than becoming an avoidable regulatory finding. Our SEBI Intermediary Compliance practice can review your existing grievance framework or help you build one from scratch.
This article is for general informational purposes and reflects the regulatory position as understood at the time of writing. It does not constitute legal advice specific to any individual's dispute — please refer to SEBI's SCORES portal (scores.sebi.gov.in) directly for the current process and forms.