PMS investor grievance redressal
The PM must resolve a complaint within 21 calendar days; after that the client escalates to SCORES and ODR.
A PMS client with a complaint has a fixed ladder to climb: first the portfolio manager, then SEBI's SCORES platform, then online conciliation and arbitration through SEBI's Online Dispute Resolution (ODR) portal. The PM must resolve a grievance within 21 calendar days of receiving it (Regulation 34A).
Distributors are often the first person a client calls when something goes wrong. Your job is to route the complaint correctly and quickly, not to resolve it yourself or talk the client out of filing it.
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The complaint path
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1. Complain to the portfolio manager
The Disclosure Document names the investor relations officer and the grievance mechanism, and PMs display a link on their website and app to lodge complaints directly. The compliance officer is responsible for redressal (Reg 34(1)). The PM must redress the grievance within 21 calendar days of receipt (Reg 34A).
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2. Escalate on SCORES
If the client is not satisfied, they can escalate through SEBI's Complaints Redress System (SCORES), on the website or mobile app. Every PMS provider must be registered on SCORES.
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3. Online dispute resolution
After these steps, or at any stage if the grievance with the PM was not resolved satisfactorily, the client can start dispute resolution on SEBI's ODR portal. Portfolio managers are listed in Schedule A of SEBI's ODR master circular.
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4. Conciliation, then arbitration
A neutral conciliator tries to settle the dispute within 21 calendar days of appointment, extendable by 10 days with consent. If that fails, the matter can go to online arbitration, where the award is due within 30 calendar days of the arbitrator's appointment.
Terms worth knowing
- ODR portal costs
- Registering a complaint on the ODR portal is free, and the conciliation fees fall on the market participant, not the investor.
- Fee disputes
- Any dispute about fees and charges is referred to arbitration under the agreement and the Arbitration and Conciliation Act, 1996 (Master Circular 7.1.2).
- Monthly complaint disclosure
- Every PM publishes data on all complaints, including SCORES complaints, on its website by the 7th of the following month (Master Circular 7.2.1).
- Investor Charter
- A SEBI document in plain language covering services, timelines, grievance redressal and the investor's own responsibilities. PMs must display it prominently on their websites and comply with it (Master Circular 4.4; Reg 23(12)).
The investor's responsibilities in the Charter
Clients sometimes complain about things the Charter puts on them. It asks investors to:
- check_circleCheck the PM's SEBI registration before investing.
- check_circleRead the agreement and the Disclosure Document before signing.
- check_circleAnswer the risk questionnaire accurately.
- check_circleStudy the quarterly statements.
- check_circleGive a complete negative list of securities and update KYC changes promptly.
Free account, this exam preselected.
30 days or 21 days?
The Investor Charter's timeline table, reproduced in the July 2025 Master Circular, still says grievances are redressed within 30 days. Regulation 34A, inserted by SEBI's grievance redressal amendment in 2023, sets 21 calendar days. The regulation is the binding rule; older material quoting 30 days is out of date.
How XXI-A tests this
Expect order-of-escalation questions (PM first, then SCORES, then ODR), who in the PM handles grievances (the compliance officer, with the investor relations officer named in the Disclosure Document), and which ODR stages cost the investor nothing. Scenario questions describe a client unhappy with the PM's reply to a complaint about unauthorised trades; the answer is escalation through SCORES or the ODR portal, not a court as the first step. The trap is choosing APMI as the complaint forum; APMI is an industry body, not the redressal route for a client.
FAQs
How do I complain against a PMS?expand_more
Complain to the portfolio manager first. If it is not resolved, escalate on SEBI SCORES, and then start conciliation and arbitration on SEBI's online dispute resolution portal.
How long does a PMS have to resolve a complaint?expand_more
21 calendar days from receipt of the grievance, under Regulation 34A of the Portfolio Managers Regulations.
Is SEBI's ODR portal free for investors?expand_more
Filing a complaint is free, and conciliation fees are borne by the market participant. Arbitration fees depend on the claim and the stage.
Where is the PMS Investor Charter published?expand_more
On each portfolio manager's website, where SEBI requires it to be displayed prominently.