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THE FINANCEBASE List yours

Guide

How SEBI Handles Complaints About Unregistered Investment Schemes

By TheFinanceBase Team 8 min read

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SEBI does not process complaints about unregistered or unregulated investment activity through the ordinary SCORES grievance route. For an alleged unregistered Collective Investment Scheme (CIS), SEBI’s CIS FAQ instructs investors to send a documented complaint by post to a SEBI office. SEBI can then examine the facts under Section 11AA of the SEBI Act, 1992 and the SEBI (Collective Investment Schemes) Regulations, 1999. This is an examination and regulatory process, not a promise that SEBI will adjudicate a private dispute or recover your money.

First, identify which kind of complaint you have

The correct route depends on whether the operator is a SEBI-regulated entity and whether your submission is a personal grievance or information about possible securities-law violations. An arrangement may be described as an “investment plan,” “membership,” “land scheme,” “profit-sharing program” or another product rather than a CIS. The label alone does not decide the legal classification. Your complaint should describe how money was collected, who controlled it, what activity was promised and what return or benefit was represented.

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Situation Where to submit What SEBI’s process does Time framework
Registered Collective Investment Management Company (CIMC) grievance Approach the CIMC first; use SCORES if the response is absent or unsatisfactory Facilitates redressal with the regulated entity; does not adjudicate the private dispute The CIMC is expected to take adequate steps within one month. SCORES 2.0 has stated response and review windows.
Alleged unregistered CIS or other unregistered activity Send a complaint by post to a SEBI office, with supporting evidence Examines the alleged activity under Section 11AA and the CIS Regulations, 1999 No equivalent SCORES service-level promise applies to the unregistered operator.
Information about a possible securities-law violation rather than a personal grievance SEBI may direct the information to its Market Intelligence Portal Can be treated as confidential market intelligence rather than a SCORES complaint Not a SCORES grievance timetable.

SEBI’s SCORES FAQ expressly says that “Complaints about any unregistered/ un-regulated activity” are not treated as SCORES complaints. Filing such a report as though it were an ordinary intermediary grievance can therefore lead to the wrong process or exclusion.

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Why an unregistered CIS complaint is sent by post

SEBI’s CIS FAQ states: “With regard to unregistered Collective Investment Schemes: Investors may send their complaint by post to any of the SEBI offices…” The same FAQ says the matter would be examined under Section 11AA of the SEBI Act, 1992 and the SEBI (Collective Investment Schemes) Regulations, 1999.

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Postal submission gives SEBI a signed, document-backed record for conduct that is outside the normal SCORES workflow. Use the current office addresses listed in SEBI’s investor and CIS contact information. Because addresses and internal routing can change, verify the destination before mailing and keep the evidence of delivery.

What to do before you contact SEBI

Preserve every piece of evidence

Do not rely on a screenshot or a verbal account alone. Make a duplicate set of the material you will send and keep the originals safely. Useful records include:

  • The offer document, brochure, application form, agreement, receipt or certificate.
  • Bank statements, cancelled cheques, UPI records, wallet statements and transfer confirmations showing each payment.
  • Advertisements, social-media posts, websites saved as PDFs, presentations and messages describing returns, benefits or buy-back promises.
  • Emails, chat exports, call details and letters exchanged with the operator, agent or promoter.
  • The legal name, trading name, office and residential addresses, telephone numbers and identities of agents or promoters.
  • A schedule of payments, promised maturity dates, amounts received back and amounts still outstanding.

SEBI’s SCORES FAQ excludes incomplete or unspecified complaints and allegations without supporting documents. Although an unregistered-CIS submission is not an ordinary SCORES complaint, the same discipline makes a postal complaint usable: identify the conduct and attach evidence that lets SEBI verify it.

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Write a fact-specific chronology

Prepare a dated timeline. State when and where you first encountered the offer, who made the pitch, what you were told, when you paid, where the money went, what return or service was promised, when payment was due and what happened after you sought repayment. Distinguish what you personally observed from what another investor told you. Avoid conclusions such as “this is definitely a Ponzi scheme” unless you explain the facts supporting that description.

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Describe the arrangement, not just the loss

Explain whether money from multiple people was pooled; whether the operator or another person managed or deployed it; whether the arrangement involved acquiring, managing or disposing of assets; and what consideration, profit, income or other benefit was represented. These facts help SEBI assess whether the arrangement may fall within Section 11AA. Include the number of participants or locations only if you can support those details.

How to send an unregistered-CIS complaint to SEBI

  1. Address the letter to SEBI. Use a current SEBI office address identified in the investor/CIS contacts and mark the subject clearly, for example, “Complaint regarding alleged unregistered Collective Investment Scheme.”
  2. Identify yourself and the operator. Give your name, postal address, telephone number and email, then list the operator’s legal and trading names, addresses, promoters or agents and all known contact details.
  3. Summarize the scheme. State the scheme name, dates, amount paid, payment method, promised returns or benefits, maturity or withdrawal terms and the amount not returned.
  4. Explain why you believe it may be unregistered. State what registration or licence was represented, if any, and what you found or were told about the operator’s status. Do not claim a status you cannot verify; describe the source of your information.
  5. Attach an indexed evidence bundle. Number the documents and refer to those numbers in the chronology. Include copies rather than irreplaceable originals.
  6. Specify the action you seek. Ask SEBI to examine the arrangement and the operator’s compliance under the applicable securities laws. You may request that SEBI acknowledge receipt or tell you how the matter has been recorded, but do not frame the letter as a demand that SEBI decide your private contract.
  7. Mail it using a trackable service. Keep the postal receipt, tracking result, a complete copy of the letter and every enclosure. If several investors are involved, each person should preserve their own payment records and explain their individual loss.

SEBI’s CIS FAQ does not create a fixed one-month or 21-day deadline for an unregistered operator. Processing time can depend on the facts, the documents and any investigation required.

When the Market Intelligence Portal may be more appropriate

A submission that mainly supplies information about suspected securities-law violations, without asking SEBI to resolve your individual grievance, may be treated as confidential market intelligence. SEBI’s SCORES FAQ indicates that such information can be directed to the Market Intelligence Portal instead of processed as a SCORES complaint.

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You can explain both elements when appropriate: provide the personal payment and non-repayment details in a complaint, and separately identify broader conduct that may affect other investors. Keep the two purposes clear. A market-intelligence report is not a substitute for preserving your evidence or pursuing a private legal remedy.

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How the Section 11AA assessment works in practical terms

Section 11AA focuses on the substance of an arrangement. Your account should therefore answer four practical questions:

  • Pooling: Were contributions from several investors pooled into a common arrangement?
  • Management or investment: Did the promoter or another person manage, operate or invest the pooled property or money?
  • Investor control: Did participants lack day-to-day control over the property, business or investment activity?
  • Consideration or return: Was a profit, income, produce, property, service or other benefit promised in exchange for the contribution?

These questions are not a self-diagnosis or a guaranteed legal result. SEBI will determine the classification from the actual documents and conduct. A scheme’s name, incorporation as a company or use of a contract does not by itself establish that it is registered or exempt.

What changes when the CIMC is registered

If the scheme is operated by a registered Collective Investment Management Company, the CIS FAQ says you should first approach that CIMC. It must take adequate steps to redress the grievance within one month. If the response is missing or unsatisfactory, you can take the grievance to SCORES.

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SCORES 2.0 timelines—and their limits

For matters that are within SCORES’ regulated-entity scope, SEBI’s investor guidance describes these windows:

  • The concerned entity has 21 calendar days to submit an Action Taken Report.
  • The complainant has 15 days to seek a first-level review.
  • A further 15-day window is available for a second-level review by SEBI.
  • A complaint should generally be lodged within one year of the cause of action.

Those periods govern the SCORES workflow for eligible regulated-entity complaints. They do not impose a 21-day response requirement on an unregistered investment scheme and do not guarantee that an unregistered-CIS postal submission will be completed within those periods.

What SEBI can and cannot do for you

SEBI describes SCORES as “a facilitator of redressal of complainant’s grievance from SEBI regulated entities” and says it “does not adjudicate disputes between the complainant and the entity.” The same limitation matters when you report an unregistered scheme: regulatory examination is different from a court judgment on liability, contract terms or damages.

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SEBI may examine the arrangement, seek information and take regulatory or enforcement steps where the facts and law support them. The available material does not establish a scheme-specific recovery rate, success rate or average payout, and no such result should be assumed.

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If you need a binding decision or compensation, consider the route that fits your legal relationship and evidence. SEBI’s FAQ identifies Online Dispute Resolution, consumer courts or other appropriate civil remedies as possible avenues when a complainant remains dissatisfied. A lawyer can help determine limitation periods, jurisdiction, parties and the evidence needed for a claim.

Common mistakes that weaken an unregistered-scheme report

  • Using SCORES as the only channel: Ordinary SCORES excludes unregistered or unregulated activity.
  • Sending a bare allegation: A name and a loss figure without agreements, payment records or a chronology may be treated as incomplete or unspecified.
  • Confusing a company registration with SEBI registration: Incorporation or a tax registration does not establish authorisation to run a CIS.
  • Expecting a private debt collection service: SEBI’s regulatory process does not adjudicate your contract or promise repayment.
  • Mailing originals: Send copies and retain a complete, indexed file.
  • Assuming the SCORES clock applies: The 21-day and 15-day windows are for eligible SCORES matters, not an unregistered-CIS postal complaint.
  • Waiting while records disappear: Save advertisements, account statements and messages promptly, and record the dates of calls and meetings.

Keeping track after mailing the complaint

Retain the tracking number and note the delivery date. Keep a log of any acknowledgement, request for information or contact from SEBI, the operator or an intermediary. Respond to requests with copies that match your index and identify any new payment or repayment event. If your address, telephone number or email changes, notify the office handling the matter so that correspondence is not missed.

Do not publish other investors’ personal data when sharing warnings online. Preserve evidence lawfully and redact account numbers or identity documents when a full copy is not necessary for the recipient.

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SEBI contact help for SCORES questions

SEBI’s SCORES FAQ lists toll-free numbers 1800 266 7575 and 1800 22 7575. The listed hours are 9:00 a.m. to 6:00 p.m. on non-holiday days. These numbers can help with platform or process questions, but the FAQ’s exclusion of unregistered or unregulated activity remains controlling. For an alleged unregistered CIS, follow the postal instruction in the CIS FAQ and retain proof of delivery.

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