A listed company has 21 calendar days to resolve an investor complaint received through SCORES and upload its Action Taken Report. That single number governs the whole escalation chain, and missing it moves the complaint out of the company's hands automatically.
This is set by SEBI circular SEBI/HO/OIAE/IGRD/CIR/P/2023/156 dated September 20, 2023, which took effect on December 04, 2023 and rescinded the earlier SCORES master circular of November 07, 2022.
The four timelines
SCORES runs on a fixed clock with four stages. Each one starts automatically.
- 21 calendar days — the entity resolves the complaint and uploads the Action Taken Report on SCORES, counted from the date the complaint is received. The circular states that entities "shall resolve the complaint within 21 calendar days of receipt of such Complaint."
- 15 calendar days — the complainant may request a first review, counted from the date of the ATR. If the complainant is satisfied, or does not seek review, the complaint is disposed of on SCORES.
- 10 calendar days — the Designated Body submits the revised ATR to the complainant on SCORES, counted from the date the review was sought.
- 15 calendar days — the complainant may seek a second review, counted from the date the Designated Body submitted its ATR. SEBI may then take cognizance.
What changed, and why it matters operationally
Three things in the 2023 framework change how a company and its RTA have to work.
Complaints are auto-routed. A complaint lodged on SCORES is forwarded to the entity automatically, and simultaneously to the relevant Designated Body. Nobody triages it in first. The 21-day clock starts on receipt.
Escalation is automatic on a miss. The circular is explicit that where the entity "has not submitted the ATR within the stipulated time of 21 calendar days," the Designated Body takes cognizance for first review. There is no grace period and no request to escalate — a missed deadline is itself the trigger.
A second-review complaint is not closed by filing an ATR. SEBI's position is that such a complaint is treated as resolved or disposed "only when SEBI 'disposes' or 'closes' the Complaint in SCORES," and that "mere filing of ATR with respect to SEBI review complaint will not mean that the SEBI review complaint is disposed."
The Designated Body also monitors ATR quality across the entities in its domain and may issue advisories or caution letters for non-redressal, and refer matters to SEBI for enforcement.
What this means for the RTA relationship
Most SCORES complaints against a listed company are registry matters — transmission, dematerialisation, a duplicate certificate, a bank-detail update, an unencashed dividend. The company carries the compliance record, but the RTA does the work that closes the complaint.
That makes RTA response time a compliance input, not an operational preference. A registry that takes three weeks to produce an answer leaves no room inside a 21-day window for the company to review it, draft an ATR and upload it.
RCMC responds to an investor grievance within 30 days of receipt as a matter of its published Investor Charter obligation, and works to the SCORES clock where a complaint arrives through that route. Our service timelines are published in full in the RCMC Investor Charter, and the escalation path for raising a matter with us is set out in our escalation matrix.
Source: SEBI circular SEBI/HO/OIAE/IGRD/CIR/P/2023/156 dated September 20, 2023, Annexure I. Effective December 04, 2023. Verified against the circular text on 03 September 2026. If you believe anything here is inaccurate, write to [email protected] and we will correct it.