The Securities and Exchange Board of India (SEBI) continues to strengthen investor protection in the Indian securities market. SEBI circulars issued on May 07, 2024 (Master Circular for RTAs ) and May 14, 2025 (Investor Charter for RTAs ) highlight SEBI’s ongoing commitment to enhancing transparency, efficiency, and grievance redressal mechanisms for investors dealing with Registrar to an Issue and Share Transfer Agents (RTAs).
While the fundamental vision, mission, and core services outlined in the Investor Charter for RTAs remain consistent, the latest circular dated May 14, 2025, introduces crucial updates, particularly in the realm of investor grievance redressal. This newsletter highlights the key differences and provides actionable insights for listed companies.
Investor Charter for RTAs: What’s New?
The Investor Charter for RTAs, as initially included in the Master Circular dated May 07, 2024, sets out the vision, mission, services, and rights/responsibilities for investors and RTAs. However, the subsequent circular dated May 14, 2025, explicitly modifies this charter, driven by advancements in the securities market and the introduction of new digital platforms
Key Differences Highlighted:
- Integration with SCORES 2.0: The updated investor charter explicitly refers to SCORES 2.0 as the new platform for lodging investor grievances against listed company/RTA. While the previous charter broadly mentioned “scores.gov.in”, the updated reference signifies the transition to the next generation of SEBI’s complaint redressal system, promising a more streamlined and efficient process.
- Introduction of Online Dispute Resolution (ODR) Platform: A significant new avenue for investors is the explicit inclusion of the Online Dispute Resolution (ODR) portal (ODR.sebi.gov.in). May 14, 2025, circular states that investors can now take recourse to this platform for dispute resolution post exhausting existing avenues of greivance redressal. SEBI has further highlighted detailed process of resolving compliant through ODR process mechanism providing timeline and stages of resolving compliant [company level, conciliation and arbitration].
- Defined Resolution Timelines for RTAs: The new Investor Charter specifies clear timelines for RTAs to resolve complaints. Complaints received through SCORES are to be responded and resolved within 21 calendar days. Investor charter has asked RTAs to process investor service requests in a timely manner and provide details / discrepancies to investors in one go. RTAs have been advised to redress grievances received through letters, SCORES and e-mails. Investor charter for RTAs is in line with principle of LODR[1] which provides for having investor grievance redressal mechanism.
Enhanced Complaint Disclosure Formats:
The updated charter places greater emphasis on structured and detailed disclosure of investor complaints by RTAs. This includes specific formats for reporting category-wise resolution data, trends of monthly complaint disposal, and average resolution times. This aims to bring more transparency to the grievance handling performance of RTAs
Actionable for Listed Companies
These updates to the Investor Charter for RTAs have direct implications for listed companies, who engage RTAs for their shareholder services. Companies should ensure they are aligned with these new requirements to safeguard investor interests and maintain regulatory compliance.
- Rights of investors to be taken care of while redressing investor grievance: Investor charter identifies rights of investors against listed companies and RTAs. It is necessary for a listed company to ensure that rights of investors are taken care of while redressing grievances of investors[1]. It is also necessary to ensure that services rendered by RTAs to investors are in line with the rights of investors.LODR also specifies rights available to investor. Rights to investors as specified in SEBI LODR are aligned with investor charter for RTAs.
- Align Internal Grievance Processes: Companies should always ensure that their own investor grievance redressal processes are updated in accordance with updated RTA charter. This includes ensuring internal teams are aware of the new timelines for complaint resolution and the escalation paths involving SCORES 2.0 and ODR.
- Communicate with Shareholders: It is recommended to proactively inform shareholders about the updated investor charter and the enhanced digital avenues for grievance redressal (SCORES 2.0 and ODR). This can be done through company websites, annual reports, and investor communication channels. Ensuring shareholders are well-informed empowers them to utilize these mechanisms effectively. RTAs also have been asked to bring to the notice of shareholders the investor charter by disseminating the same on their websites/ emails etc.
- Leverage Digital Platforms: Understand how SCORES 2.0 and the ODR platform work. While RTAs are the primary interface for many shareholder services, listed companies play a crucial role in overall investor satisfaction and resolving escalated matters. Familiarity with these platforms will facilitate smoother resolution of any investor-related issues.
- Maintain Accurate Shareholder Records: Emphasize the importance of accurate and up-to-date shareholder records with the RTA, including PAN, KYC details, and nomination details, as these are prerequisites for seamless service requests and grievance processing as per SEBI norms. Investor charter also states that investors shall provide documentation complete in all respects for availing any investor service request.
Conclusion
By taking these proactive steps, listed companies can ensure robust investor protection, foster trust, and effectively manage their shareholder relationships in line with the evolving regulatory landscape
RTA investor charter can be accessed at below link:
[1] Reg. 4(2)(a)(vii) – listed company to provide adequate mechanism to address grievances of the shareholders
[2] Viz. right to get fair treatment [4(2)(c)], right to get updates with respect to various service requests filed with the RTA, right to have access to escalation matrix for communication with RTA, right to sell/transfer securities with minimal documentation, right to ask for and receive information about all statutory and regulatory disclosure [4(2)(d)(iii), right to get customized service at fair price etc.