SCORES 2.0 Authentication & Compliance for SEBI Intermediaries: A Complete Practical Guide

Investor grievance redressal lies at the core of the regulatory framework of the Securities and Exchange Board of India (SEBI). Every listed company, SEBI-registered intermediary and Market Infrastructure Institution is expected to have a structured system to receive, track and dispose of investor complaints within fixed timelines.

SEBI has put in place the SEBI Complaint Redress System, commonly known as SCORES, to standardise and monitor this process. For intermediaries, access to SCORES is not optional – it is a mandatory part of their regulatory compliances and is technically referred to as SCORES Authentication (though many professionals informally call it “SCORES Registration”).

This article provides a fully restructured and practical guide for SEBI intermediaries on:

What SCORES and SCORES 2.0 actually are
How authentication is linked to SEBI registration
Which entities must obtain authentication
Practical steps to secure access, maintain profile accuracy and handle complaints
Consequences of non-compliance, including review mechanisms and enforcement risk
Internal controls and SOPs that every compliant intermediary should maintain

1. SCORES Platform – Concept, Scope and Regulatory Role

1.1 What SCORES Means in Practice

SCORES (SEBI Complaint Redress System) is SEBI’s official online platform for:

Filing investor grievances against:
- Listed companies
- SEBI-registered intermediaries
- Market Infrastructure Institutions
Routing complaints automatically to the concerned regulated entity
Tracking the lifecycle of each complaint, including:
- Response of the entity
- Action Taken Report (ATR)
- Review requests and decisions

SEBI describes SCORES as a facilitative grievance-redressal mechanism, not as a substitute for courts, arbitration, consumer forums, or other adjudicatory processes. It is essentially a regulatory supervision and accountability tool that forces timely and documented responses to investor grievances.

1.2 Objectives of SCORES

SCORES is intended to:

Prevent complaints from being ignored or indefinitely delayed
Fix strict timelines for redressal and ensure automatic escalation if timelines are missed
Provide full transparency to:
- Investors – by allowing real-time status tracking
- Intermediaries – via an Entity Dashboard showing pending complaints and deadlines
Enable regulatory oversight, allowing SEBI and Designated Bodies to see whether an intermediary:
- Responds within time
- Provides complete and satisfactory ATRs
- Shows recurring patterns of weak grievance-handling practices

Important: Every complaint on SCORES should be treated as a regulatory compliance issue, not just a customer-service ticket.

1.3 Types of Complaints Suitable for SCORES

Investors can raise a wide range of securities-market related grievances, such as:

Non-receipt of funds, securities or documents
Unauthorised transactions or trades
Incorrect or excessive charges
Delay in execution of instructions
Non-payment of dues / payouts
Failure to update KYC or client details
Misrepresentation or poor advisory / research service
Non-response to an earlier written grievance

The specific nature of typical complaints depends on the intermediary’s category and the activity permitted under its SEBI registration (e.g., stock broker vs. portfolio manager vs. investment adviser).

1.4 Matters That Need Other Forums

SCORES is not designed to adjudicate complex legal disputes. Complaints may be disposed of on SCORES when:

They involve disputed legal rights or detailed evidence
Adjudication is required (e.g., contested contractual liability)
The complainant opts for:
- Online Dispute Resolution (ODR)
- Arbitration
- Consumer commission
- Civil court or any other appropriate forum

In such cases, SCORES will reflect closure of the complaint with an advisory to pursue, or continue with, the appropriate legal forum.

2. SCORES 2.0 – New Framework and Features

2.1 Launch of SCORES 2.0

An upgraded version of the platform, SCORES 2.0, was rolled out in April 2024. The primary intent is to:

Reduce manual intervention
Strengthen tracking and monitoring
Enforce time-bound redressal via automation and reviews

Key changes include automatic routing, dashboard-driven timelines, and a structured two-tier review mechanism.

2.2 Automatic Assignment of Complaints

Under SCORES 2.0:

When an investor files a complaint, it is automatically mapped and assigned to the relevant entity based on:
- Registration category
- Profile information
This saves time otherwise lost in manual forwarding and instantly places responsibility on the concerned intermediary.

However, this automation will work correctly only if:

The entity’s registration category is accurate
Its SCORES and SEBI records are properly mapped

Incorrect or outdated profile data can cause misrouting or missed complaints.

2.3 Time-Bound Redressal – 21 Calendar Days

Every intermediary must file its Action Taken Report within 21 calendar days of receiving the complaint on SCORES.

Critical Point: “Calendar days” includes Saturdays, Sundays and public holidays. The assessee should not interpret this as 21 working days.

Internal processes should therefore aim at much shorter timeframes (e.g., 10–15 days) to leave buffer for review and approvals.

2.4 Dashboard-Based Monitoring

The Entity Dashboard shows:

All complaints pending with the intermediary
Age of each complaint
Remaining time before the 21-day deadline expires

Although the dashboard is a powerful monitoring tool, entities should also maintain their own internal complaint tracker, so that:

Responsibility can be assigned and recorded
Approvals and follow-ups can be documented
Dependencies on portal availability are minimised

2.5 Two-Level Review Mechanism

SCORES 2.0 builds in a structured review framework:

First-Level Review
- Triggered when:
  - The investor is dissatisfied with the ATR, or
  - The intermediary fails to submit ATR within 21 calendar days
- Conducted by:
  - The relevant Designated Body, or
  - SEBI (where no Designated Body exists)
Second-Level Review (by SEBI)
- Available when:
  - The investor is still dissatisfied after first-level review, or
  - The Designated Body itself fails to respond within stipulated time
- SEBI may:
  - Call for revised ATR
  - Seek additional clarification
  - Examine the entire record before closing the complaint or advising parties to move to other forums

3. SCORES Authentication vs SEBI Registration

3.1 Why It Is Called “SCORES Registration” in Practice

Professionals informally use the phrase “SCORES Registration” because an entity needs portal access after it is registered with SEBI. However, technically SEBI refers to this as SCORES Authentication, i.e., allotment of:

Entity-specific user ID
Password linked to the SEBI registration number

3.2 Distinguishing SEBI Registration from SCORES Authentication

SEBI Registration
- Allows an applicant to carry out a regulated activity (e.g., Portfolio Manager, Investment Adviser, Research Analyst, Merchant Banker, etc.).
SCORES Authentication
- Provides login access to the SCORES portal to:
  - View complaints assigned to that registration
  - Submit ATRs
  - Respond during review stages

SCORES authentication is therefore a post-registration access requirement, not a substitute for or equivalent to SEBI registration.

3.3 Entity Authentication vs Investor Account

Two very different types of SCORES access exist:

Investor Account
- Created by investors to lodge complaints
- Based on personal/KYC details
Entity Authentication
- Issued to listed companies, intermediaries and MIIs
- Linked to SEBI registration number and category
- Gives access to the Entity Dashboard

An assessee must never use an investor login (even if in the name of its compliance officer) to manage complaints.

Mandatory SCORES 2.0 Authentication for SEBI Intermediaries: End‑to‑End Compliance Guide