SEBI Expedites Investor Complaint Redressal Under SCORES

The Securities and Exchange Board of India (SEBI) recently issued a circular[1] on redressal of investor complaints through SCORES (SEBI Compliant Redressal System) and linking it to online dispute resolution platform. This is to enhance efficiency by reducing processing times and implementing automated routing and escalation mechanisms for addressing investor complaints against listed companies, registered intermediaries, or market infrastructure institutions.

The SCORES is a centralised facilitative platform which was introduced in the year 2011 to resolve the investor’s complaints against entities functioning in the securities market. SEBI has subsequently revised and strengthened the grievance redressal system on SCORES. These updated regulations for investor grievances are designed to ensure compliance with the revised SEBI (Facilitation of Grievance Redressal Mechanism) Regulations, 2023.[2]

Grievance Redressal Mechanism

The investors who wish to file a complaint must register on the SCORES portal under ‘Investor Corner’. The investors’ details, including PAN and contact details, are required for effective and speedy redressal communication. Additionally, the investors may complain against any entity within one year of the occurrence of the cause of action. SEBI may reject any complaint filed once the period of limitation is over. Moreover, certain complaints will not be dwelt via SCORES, such as complaints against delisted companies or companies on the Dissemination Board of Stock Exchange (except securities valuation complaints), matters before judicial or quasi-judicial or other dispute resolution forums, complaints under other regulatory bodies purviews, complaints against companies under resolution under the Insolvency and Bankruptcy Code, 2016, companies struck off from Register of Companies, liquidated companies and companies regarding market intelligence.

Complaints Redressal

Starting from December 4, the new framework requires that complaints submitted through SCORES be resolved within 21 days. These complaints are automatically sent to the relevant entity for resolution and designated bodies for monitoring. These bodies ensure that the entities submit an Action Taken Report (ATR) within 21 days, which is auto-routed back to the complainant. If the investor is still unsatisfied, they can request a review within 15 days of receiving the ATR.

First Review

If a review is requested or entities fail to submit the ATR within 21 days, the designated body overseeing the complaint takes charge of the initial review process via SCORES. The entity must submit the ATR within the stipulated time and provide the requested clarifications. The designated body reviews the revised ATR and sends it to the complainant within ten days. Moreover, SEBI shall take cognisance if intermediaries without designated bodies are appointed.

Second Review

Investors can request a second review within 15 days of receiving the revised ATR if they are still dissatisfied or if the designated bodies fail to submit it within ten days. In such cases, SEBI may handle the complaint for the second review via SCORES. SEBI engages with the entity and/or designated body for immediate action and ATR submission. The second review complaint is marked ‘closed’ or ‘disposed’ when SEBI completes its actions in SCORES.

Registration On Scores

SEBI provides an entirely automated procedure for generating a SCORES user ID and password for all SEBI-registered intermediaries and market infrastructure institutions (MIIs) recognised by SEBI post-August 2019. The SCORES user ID and password are sent via email provided in the online registration form and submitted through the SEBI Intermediaries portal. Brokers and Depository Participants are also required to obtain SCORES authentication.

Designated Bodies Authentication On SCORES

Designated Bodies must submit a Schedule IV form by sending it to for SCORES Authentication from SEBI. The provided email address will receive the SCORES user ID and password. These Designated Bodies must assign a generic email ID for SCORES authentication and appoint a nodal officer whose details must be updated with SEBI via SCORES or email. Designated Bodies can contact SEBI at to integrate their complaint redressal portal with SCORES via the Application Programming Interface (API). SCORES Authentication is required for all Designated Bodies, even API-integrated ones. Designated Bodies must have the infrastructure, systems, and manpower for compliance with the process laid down in this circular. They should also have procedures to prevent SCORES data leaks.

Designated Bodies must also maintain Management Information Systems (MIS) reports and share them with concerned entities to ensure timely Action Taken Reports. SEBI may request MIS reports in a specific format and at specific intervals as needed. SEBI can appoint or remove Designated Bodies for registered intermediaries as required.

Failure To Redress Investor Complaints By Listed Companies

The framework provides the Designated Stock Exchange (DSE) shall levy a fine of Rs.1000 a day per complaint on the listed company for violation to ensure expeditious redressal of investor complaints.[3] Fines will also be levied on companies suspended from trading on the Stock Exchange. The DSE will notify a listed company, informing them of the penalties imposed and directing them to submit ATR on pending complaints and pay fines within 15 days. If the company fails to comply with either, the DSE will notify the company’s promoters to ensure compliance within ten days. Failure to meet these requirements will lead depositories to freeze the promoters’ shareholding and other securities in their demat accounts. The depository will inform the promoters of the non-compliance. The DSE may take further action if the company still doesn’t resolve complaints or pay fines. The fine accrues monthly until the complaints are resolved, or the company is delisted. If there are over 20 pending complaints or the value exceeds Rs. 10 lakhs, the cases are forwarded to SEBI. Stock exchanges can deviate from this procedure with written reasons, and they must inform SEBI about the actions taken. The Stock Exchange must necessarily inform SEBI via SCORES of all actions taken against listed companies for non-compliance.





[3] Regulation 13 (1) of SEBI (Listing Obligation and Disclosure Requirements) Regulations, 2015 (LODR Regulations) read with SEBI circular no. SEBI/HO/CFD/CMD/CIR/P/2020/12 dated January 22, 2020,


IBBI Amendment Regulations: Key Changes

Several amendments to the Insolvency and Bankruptcy Board of India (IBBI) regulations were notified by the Board on September 18, 2023.

Under the Insolvency and Bankruptcy Board of India (Model Bye-Laws and Governing Board of Insolvency Professional Agencies) (Amendment) Regulations, 2023, a unified enrolment and registration application form is to be launched so that a common application form can be filed for both enrolment and registration processes. The unified application for enrolment has to be approved within 60 days and the unified application for registration has to be forwarded to the Board within 30 days.

The Board has also amended the 2016 regulations on insolvency professionals.[1] Before accepting applications for surrender of professional membership or expelling a professional member, compliance with certain requisites pertaining to fee payment, disciplinary order, etc. must be ensured. Further, the insolvency professionals would be permitted to surrender their registration certificate to the Board, through the introduction of Regulation 10A.

The amendment regulations on the insolvency resolution process for corporate persons provide for additional responsibilities of the Authorised Representative (AR) to facilitate the class of creditors, especially home buyers; review of contents of minutes prepared by the Resolution Professional (RP), providing regular updates to the creditors in a class on the progress of the CIRP, etc.[2] Accordingly, the AR’s fee will also be increased. The committee members will be able to get an audit of the Corporate Debtor (CD) done and such audit costs will be included in the CIRP cost. If the debt has been assigned by the creditor to another person, the creditor has to provide the details of such assignment to the RP within 7 days.




RBI Releases Draft Master Directions on Treatment of Wilful Defaulters

The Reserve Bank of India (RBI) has come out with draft master directions on the treatment of wilful defaulters and large defaulters. The directions will come into force after 90 days.

These directions, which have broad consequences for financial institutions, borrowers, auditors, and other stakeholders, are based on important financial regulations. The main goal of these guidelines is to create a fair and just procedure for identifying wilful defaulters, in line with natural justice principles. The RBI aims to make it easier for lenders to consider providing additional financial aid to wilful defaulters by facilitating the exchange of credit information about them.

The document contains important clauses pertaining to its applicability to different financial organizations, such as banks, non-banking financial companies (NBFCs), asset reconstruction companies (ARCs), and credit information companies (CICs). In Chapter II, the concept of wilful default is defined, along with the methods for locating and evaluating wilful defaulters. Additionally, it provides for harsh penalties and processes that are transparent. Chapter III discusses the significance of providing accurate and timely information to credit information businesses and outlines the repercussions of failing to do so. Although the document’s primary attention is on wilful defaulters, it also contains measures pertaining to large defaulters that are in line with the RBI’s prudential standards on income recognition, asset categorization, and provisioning.

The functions of identification and review committees, protections for part-time directors, sanctions against wilful defaulters, and guarantors’ liabilities are a few significant elements. It covers the reporting duties to credit information firms and the handling of compromised settlements. In addition, it recognises the importance of third parties, including statutory auditors, in identifying, preventing, and correcting wilful defaults. When necessary, these parties would be held accountable. It also necessitates the reporting of guarantors and directors connected to the borrower and encourages preventive actions during credit appraisal and monitoring, emphasising the accuracy of reporting.



NMC Global Recognition: Indian Medicos Can Now Practice Abroad

The National Medical Commission (NMC) has received the World Federation for Medical Education (WFME) recognition status, thereby enabling Indian medical graduates to pursue postgraduate studies and practice abroad. The recognition will be valid for a period of 10 years.

This global recognition is expected to not only improve the reputation of Indian medical colleges and professionals but also to promote innovation in medical education and facilitate academic collaborations, exchanges, etc.

In the press release dated September 20, 2023, it is stated that such an accreditation will enable Indian students to pursue PG training and practice in other countries that require WFME recognition, which include the United States, Canada, Australia, and New Zealand. They will also be eligible to apply for the Education Commission on Foreign Medical Education and the United States Medical Licensing Examination. It is said that an official award letter and a certificate will also be provided by the Federation in the days to come.

Further, the existing medical colleges in India will become WFME accredited and the new medical colleges that will be set up in the coming 10 years will automatically become WFME accredited.


Self-Regulatory Mechanism for News Channels to be Strengthened

In an order dated September 18, 2023, the Supreme Court in the case of News Broadcasters Association v. Union of India & Ors. [SLP(C) Nos. 17959-17960/2023] expressed the need to strengthen the self-regulatory mechanisms for news channels. Accepting the request of the petitioners, the Court granted four weeks’ time for preparing and presenting the proposed regulations before the Court.

Referring to the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, the respondents submitted that the Central Government had a mechanism in place which operated at three tiers, the first being self-regulation.

The Court questioned the effectiveness of the current self-regulatory mechanism which provides for the imposition of a Rs. 1 Lakh fine on the channels. Terming it as lenient, the Court specified that it needed “some teeth”. The Division Bench of Chief Justice D Y Chandrachud, Justice J B Pardiwala and Justice Manoj Misra held that self-regulation “needs to be tightened up to bring some kind of discipline”.

However, the Court clarified that it did not intend to impose any pre-censorship or post-censorship on the media. With this, the Court granted four weeks’ time to formulate and present the proposed regulations.

The matter will be heard next on October 20, 2023.


Govt Should Consider Setting Age Limit for Using Social Media: HC

While hearing a writ appeal filed by X Corp concerning certain blocking orders, the Karnataka High Court remarked that the Central Government should consider setting an age limit for the use of social media.[1]

Pointing out that school-going children are addicted to social media, Justice G Narendar opined that an age limit should be put in place, “as in the Excise rules”. He further stated, “When a user registers, he will have to give some material, just like in online gaming where a person not having Aadhar etc. cannot join. Why don’t you extend it here also? It will be a boon”.

Earlier, X Corp had approached the Single Judge Bench of the Karnataka High Court, challenging the blocking orders issued by the Ministry of Electronics and Information Technology (MeitY) under Section 69A of the Information Technology Act, 2000. The blocking orders were issued between February 2, 2021, and February 28, 2022. Dismissing the plea, the Court imposed a cost of Rs. 50 Lakh. On appeal, the order passed by the Single Judge Bench was stayed, and X Corp was directed to deposit Rs. 25 Lakh.

When the interlocutory applications were taken up for consideration yesterday, X Corp requested that the blocking orders be reconsidered by the Central Government. In this regard, the Court has sought the Centre’s response.

The matter will be heard next on September 27, 2023.

[1] X Corp. v. Union of India & Ors. (WA 895/2023)


IRDAI Sets Up Standing Committee on Cyber Security

The Insurance Regulatory and Development Authority of India (IRDAI) has set up an inter-disciplinary standing committee on cyber security. The committee is expected to regularly review the threats inherent in the existing or emerging technologies and suggest appropriate changes to the IRDAI Information and Cyber Security Framework to further strengthen the insurance industry’s cybersecurity posture and resilience.

This decision was taken pursuant to the release of the IRDAI Information and Cyber Security Guidelines dated April 24, 2023. The said guidelines sought to ensure the security of the organisation’s information assets through the effective implementation of up-to-date security mechanisms. The Office Order dated September 14, 2023, specifies that the suggestions received from the Regulated Entities (REs) in the implementation of the 2023 guidelines will also be considered by the committee for suggesting appropriate changes in the current framework.

The standing committee will consist of a chairperson, eight members and a convener. If necessary, the committee may invite external members to examine specific issues or suggestions.


BCCI Releases Policy on Prevention of Sexual Harassment

In a turning point for Indian cricket, the Board of Control for Cricket in India (BCCI) has released its policy on the prevention, prohibition, and redressal of sexual harassment. It will come into force on the date as may be notified by the Board.

The policy has been formulated as required under provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, with a view to “promote a safe working environment for all free from any sort of workplace harassment, including sexual harassment”.

Any BCCI personnel who is a woman/ man/ third gender can file a complaint under the policy. Apart from defining sexual harassment, the document provides for the constitution of an Internal Committee (IC) and lays down the procedure for making the complaint. Additionally, the BCCI has nominated members of the Internal Complaints Committee. The Committee may attempt to settle the matter through conciliation; however, it is expressly stated that “no monetary settlement shall be the basis of such conciliation”.

It is clarified that the workplace of the Board will not include events attended by BCCI personnel in their personal capacities, venues of promotional and endorsement events where the BCCI personnel are not representing the Board, etc. In case of a guilty finding, the Board would be empowered to impose penalties by directing the respondent to tender a “written apology”, undergo counselling, pay a fine, etc. Such a finding could also lead to termination of employment.

The Board would be obligated to assist the complainant in filing a criminal complaint if the complainant so desires. Further, the policy requires the Board to report offences against minors to the Special Juvenile Police Unit, or the local police, and comply with any other requirements under the Protection of Children from Sexual Offences Act, 2012, or other applicable laws.


New GST Directive Sets 30-Day Time Limit for E-Invoice Filing

The GST Authority has decided to set a 30-day time limit for invoice reporting on the Invoice Registration Portal (IRP) for taxpayers with Aggregate Annual Turnover (AATO) greater than or equal to Rs. 100 Crores. This limit will apply from the date of the invoice.

The decision to impose such a restriction has been taken with the aim to enhance compliance with GST regulations and streamline the reporting process. The advisory issued by the National Informatics Centre states that the restriction will apply to all document types requiring Invoice Reference Numbers (IRNs). This includes invoices, credit notes, and debit notes. For example, if an invoice is dated November 1, 2023, it must be reported no later than November 30, 2023.

This GST directive which will come into force w.e.f. November 1, 2023, is in supersession of the previous advisory dated April 17, 2023, through which the Centre informed of the Government’s decision to impose a 7-day time limit.


Telcos to Refund Overcharged Amount to Consumers: TRAI

On September 11, 2023, the Telecom Regulatory Authority of India (TRAI) released the Quality of Service (Code of Practice for Metering and Billing Accuracy) Regulations, 2023, which stipulate that telecom service providers must refund overcharged amounts within three months of audit findings. The said regulations are slated to become operative from April 1, 2024.

The regulations aim to strike a harmonious balance between safeguarding subscriber rights and minimising the compliance burdens placed upon service providers, thereby facilitating a more conducive environment for conducting business.

One of the key differences between the 2006 Regulations and the new regulations is that the former applied selectively to specific service providers, whereas the latter casts a broader net, encompassing all service providers while introducing more lucid licensing prerequisites. In stark contrast to its predecessor, the 2023 Regulations focus on audit and compliance.

Some of the other notable changes introduced under the new regulations are as follows: –

  • Audit Frequency Reduction – The audit frequency for licensed service areas (LSAs) has been reduced, easing the burden of audits on telecom companies, from a quarterly requirement to an annual one.
  • Broadened Audit Scope – The revised standards encompass a broader spectrum of tariff offerings, including international roaming, even for telecom companies with modest subscriber bases, a departure from previous regulations.
  • Auditor Provisions and Time Restriction – The new regulations eliminate self-evaluation provisions for auditors and extend the time limit for providing raw Call Detail Records (CDRs) from 15 to 30 days.
  • Record Retention Period – To enhance business efficiency and ensure regulatory compliance, the new regulations introduce a record retention period of one year.
  • Annual Audits – Telecom providers are mandated to undergo annual metering and billing system audits per the 2023 quality of service requirements.
  • Involvement of TRAI-Notified Auditors – The performance of these audits is entrusted to auditors notified by TRAI, signifying TRAI’s active participation in their selection and approval.
  • Monetary Penalties for Non-Compliance – Failure to adhere to audit requirements or inability to submit audit reports can result in monetary penalties of up to Rs. 50 lakhs per report for telecom businesses.
  • Submission of Annual Audit Schedule – Telecom businesses must furnish an annual audit schedule to TRAI, identifying the billing systems and LSAs earmarked for audit.
  • Reporting Overcharging – The provisions require consumers to report instances of overcharging to the service provider in writing within a week to facilitate prompt corrective action.
  • Auditor Reporting Delays – Telecom companies are shielded from punitive measures for auditor-induced delays in sharing audit details, as the onus for timely reporting rests squarely with the auditors.