SEBI has proposed a major overhaul of the ODR framework for investor disputes. Here's what retail investors need to know about the new rules, timelines and safeguards.
If you have ever raised a complaint against your broker or a listed company and felt like it disappeared into a black hole, you are not alone. Thousands of retail investors go through SEBI's grievance system every month, and while the process has improved over the years, it still has gaps that frustrate ordinary investors. That is exactly what SEBI is now trying to fix.
On July 23, 2026, SEBI released a consultation paper proposing a fairly significant overhaul of the Online Dispute Resolution (ODR) framework for the securities market. This is not a final rule yet, it is open for public comments till August 13, 2026, but the direction is clear enough that every retail investor should understand what is being proposed and why.
Retail participation in Indian markets has grown massively over the last few years. More people are trading options, applying to IPOs, and investing through mutual funds and AIFs than ever before. With more participation comes more disputes, disagreements over brokerage charges, delayed settlements, unauthorised trades, and disputes with listed companies. As retail interest in new offerings like the NSE IPO and other 2026 listings keeps growing, the number of touchpoints where something can go wrong grows with it.
SEBI's current system was already technology driven, but the regulator felt the process took too long and did not always end with a decision that stuck. Investors would win a case only to see it get delayed further during appeals. So this time, SEBI is not just tweaking timelines, it is proposing to change who actually runs the process.
Right now, if you have a grievance, you first raise it directly with the market participant, whether that is your broker, a depository participant, or a listed company. If that does not resolve things, you move to SEBI's SCORES 2.0 platform. Under this system, the entity gets 21 days to submit an Action Taken Report. If you are not satisfied, you get a first-level review within 15 days, and if needed, a second-level review by SEBI itself, again within 15 days. Only after all this can you approach the Online Dispute Resolution mechanism for conciliation and arbitration.
This layered approach sounds thorough, and it has actually worked reasonably well on paper. SEBI's own data shows the system handling thousands of complaints every month. In December 2024, the regulator resolved 5,636 complaints out of 11,019 total applications on file. By March 2025, that number had come down to 4,371 resolved complaints, and by May 2025, it stood at 4,493. The chart below shows how complaint volumes and resolutions have moved over these months.
SEBI SCORES Platform: Complaints Received vs Resolved
Monthly data reported by SEBI (number of complaints)
Source: SEBI public notices under SCORES monthly disclosures
The numbers show the system chipping away at complaints steadily, but the process of getting there, especially for complaints that need to go all the way to conciliation or arbitration, has been slower than investors would like. This is the gap SEBI's new proposal tries to close.
The consultation paper covers several changes, and it is worth going through them one by one because each affects retail investors differently.
These changes come at a time when SEBI has also been active on other fronts affecting retail investors, including its revised ETF trading framework and the return of open-market buybacks, discussed in our piece on SEBI's open market buyback rules for 2026. Taken together, these reforms suggest the regulator is trying to tighten up investor protection across the board, not just in dispute resolution.
| Aspect | Present System | SEBI's Proposed Change |
|---|---|---|
| Who administers ODR | Independent ODR institutions | Stock exchanges, depositories and clearing corporations (MIIs) |
| Arbitrator or conciliator selection | Largely assigned by the ODR institution | Both parties submit preferences, MII appoints accordingly |
| Unresolved SCORES complaints | Investor must separately initiate ODR | Escalated directly to conciliation, saving about 21 days |
| AIF investor disputes | Mandatory use of the ODR platform | Option to use pre-agreed contractual mechanism instead |
| Legal protection for AIF investors | Stronger for trust-structured AIFs | Extended equally to company and LLP-structured AIFs |
| Appeal against an investor-favourable award | No specific deposit requirement highlighted | Entity challenging the award must deposit the full amount with the MII |
| Current status | Not applicable | Consultation paper, comments open till August 13, 2026 |
On the face of it, moving administration to MIIs might sound like a technical change that does not concern individual investors much. But think about it practically. Stock exchanges and depositories already have direct regulatory relationships with brokers and listed companies. They know which entities are repeat offenders, they hold data on trading patterns, and they have the leverage to enforce compliance because these entities need exchange membership to operate. An independent ODR institution, by comparison, has none of that direct oversight power.
This is a meaningful shift for anyone who has ever felt like winning a dispute on paper did not actually translate into getting their money back or their issue fixed. It is a problem that ties closely into a broader theme we have covered before, why a large number of retail participants end up on the losing side of trades and disputes simply because the system was not built with enough teeth. If you want the fuller picture on investor vulnerability in Indian markets, our article on why 90 percent of traders lose money is worth a read alongside this one.
SEBI's own estimate is that the proposed changes could shave off around 21 days from the overall dispute resolution timeline. To put that in context, under the present multi-stage process, an investor whose complaint goes unresolved at the entity level, through the first review, and then the second review, could be looking at close to 51 days before the matter even reaches the conciliation stage under ODR. Shave off 21 days from that, and you are looking at roughly 30 days, nearly a 40 percent reduction.
How Much Faster Could Dispute Resolution Get
Illustrative timeline based on SEBI's stated process windows (in days)
This is an illustrative estimate based on SEBI's stated process windows rather than an official figure the regulator has published as a single number, but it gives you a sense of scale. For someone with money stuck in a dispute, whether it involves a few thousand rupees or amounts running into several lakh rupees, cutting three weeks off the wait is a real difference.
If you invest in Alternative Investment Funds, two changes are directly relevant to you. First, you will no longer be forced onto the ODR platform if your fund agreement already has a dispute resolution clause you are comfortable with, you can choose to use that instead. Second, and this is the more important one, if you invested through a company or LLP structure rather than a trust, you will now get the same legal protections that trust-structured AIF investors already enjoy. Until now, that gap in protection depended purely on how the fund was legally structured, which had nothing to do with the investor's actual risk or contribution.
One of the more investor-friendly proposals is around what happens when an entity, say a broker or listed company, loses an arbitration case and decides to challenge the award in court. Under the new proposal, that entity would need to deposit the full award amount with the MII before pursuing the appeal. This matters because, in the past, a losing party could drag out an appeal for months or years while the investor's money remained tied up with no guarantee of ever receiving it. Requiring an upfront deposit changes the incentive structure considerably.
Since this is still a consultation paper, nothing changes immediately for anyone with an ongoing complaint. The existing SCORES and ODR process continues to apply as is. That said, there are a few sensible things to keep in mind. Keep all your transaction records, contract notes, and correspondence with your broker or fund organised, because a well-documented complaint moves faster regardless of which process handles it. If you are already dealing with a dispute, do not wait passively, use the existing first-level and second-level review windows actively rather than letting timelines lapse.
It is also worth remembering that dispute resolution is a last resort, not a substitute for careful decision making in the first place. Good position sizing and risk management, like the kind discussed in our piece on the 3-5-7 rule for protecting your trading capital, reduces how often you end up needing SEBI's grievance machinery at all. And since 2026 has already brought several regulatory shifts that affect how retail investors operate, from buyback norms to the financial changes that came into effect from July 1, it helps to stay updated on the broader regulatory calendar rather than just this one proposal.
If you want to submit feedback on the consultation paper itself, SEBI's website accepts public comments until August 13, 2026, and any retail investor is free to weigh in before the framework is finalised.
Not yet. As of now it is a consultation paper released on July 23, 2026, and SEBI is accepting public comments until August 13, 2026, before finalising the rules.
ODR, or Online Dispute Resolution, is the stage an investor can move to after the SCORES complaint process, involving conciliation and arbitration to resolve disputes with brokers, listed companies, or other market participants.
Stock exchanges and depositories already have direct regulatory oversight over brokers and listed entities, which SEBI believes will help enforce dispute outcomes more effectively than independent ODR institutions.
SEBI estimates the changes could reduce the overall dispute resolution timeline by around 21 days, mainly by escalating unresolved SCORES complaints directly to the conciliation stage.
Yes. AIF investors will get the option to use pre-agreed contractual dispute mechanisms instead of the mandatory ODR platform, and legal protections will apply equally regardless of whether the AIF is structured as a trust, company, or LLP.
Under the proposed rules, if the entity challenges an arbitration award that favours the investor, it must first deposit the full award amount with the Market Infrastructure Institution before proceeding with the appeal.
Investors can file complaints through SEBI's SCORES platform, which is the first formal step before escalating unresolved matters to the Online Dispute Resolution mechanism.