How to Check a Company's Investor Complaint Record

A company's investor complaint record is one of the few pieces of shareholder-servicing data that every listed Indian company is required to publish, every quarter, in the same four numbers. It will not tell you what the complaints were about. It will tell you how many arrived, how many were closed, and how many are still open, and a backlog that persists across quarters is visible without any interpretation. Here is where to find it and how to read it.

Where is the investor complaint record filed?

Not where it used to be. Regulation 13(3) of the LODR Regulations was substituted by the SEBI (Listing Obligations and Disclosure Requirements) (Third Amendment) Regulations, 2024 with effect from 31 December 2024. Before that substitution, the sub-regulation itself set the deadline: within twenty one days from the end of each quarter, with the four counts written into the regulation. The current text sets no deadline at all, requiring the statement to be filed quarterly "in such form and within the timelines as may be specified by the Board".

The Board specified both by folding it into the Integrated Filing (Governance), which is due within 30 days of the end of the quarter. So the same statement now lands nine days later than it used to, alongside the corporate governance report.

If you are looking for a standalone "Investor Complaints" filing for a quarter after December 2024, you will not find one. Open the Integrated Filing (Governance) and go to Part B.

What the four counts are, and what they are not

Annexure 25 of the LODR master circular sets the format. Part B, the Investor Grievance Redressal Report, is four rows:

1. Number of investor complaints pending at the beginning of the quarter.
2. Number of investor complaints received during the quarter.
3. Number of investor complaints disposed of during the quarter.
4. Number of investor complaints remaining unresolved at the end of the quarter.

That is the whole disclosure. There is no breakdown by type, no ageing of the pending pile, no distinction between a complaint about a dividend warrant and one about a share transfer, and no names.

What it does give you is an arithmetic check across quarters. Row 1 of a quarter should equal row 4 of the previous one. Where it does not, something was reclassified, and that is worth a look at the company's own explanation.

The 21 day clock the counts sit on top of

Regulation 13(1) now reads that the listed entity shall redress investor grievances promptly but not later than twenty one calendar days from the date of receipt of the grievance. That text was substituted by the SEBI (Facilitation of Grievance Redressal Mechanism) (Amendment) Regulations, 2023 with effect from 18 August 2023. The provision it replaced said only that the entity "shall ensure that adequate steps are taken for expeditious redressal of investor complaints", with no number in it.

A dating detail worth carrying: the fine schedule in the LODR master circular still describes the Regulation 13(1) breach in that older wording, failure to ensure adequate steps for expeditious redressal, even though the regulation itself now carries the 21 day figure. Read the regulation for the duty and the master circular for the fine.

Two other obligations sit alongside:

• Regulation 13(2): the entity must be registered on the SCORES platform, or such other platform the Board mandates, to handle complaints electronically. For securitised debt instruments, SCORES registration may be taken at trustee level.
• Regulation 13(4): the statement in 13(3) must be placed before the board of directors quarterly. So the counts are not only an exchange filing, they are a board paper.

Cross-checking against the other side of the same complaint

The company's filing is a self-report. The complaint's other end sits with SEBI and the exchanges:

• SCORES runs the complaint itself, with a 21 calendar day resolution clock on the entity, an Action Taken Report, and two levels of review. For a listed company, the Designated Body monitoring redressal is the stock exchanges.
• The ODR portal is where a dispute goes after SCORES when what is really in issue is an amount.

Reading the company's four counts next to those two routes gives you the useful frame: the counts are what the company says reached it and got closed, and a complaint escalated to SEBI has already been through the number in row 3.

How to read the record without over-reading it

A large received count is not automatically a bad sign. Complaint volume tracks shareholder count, and a company with a million retail holders will report more complaints than one with ten thousand, for reasons that have nothing to do with how it treats them. Corporate actions also spike it: a dividend, a bonus or a rights issue generates servicing queries by the thousand.

The signals that survive that noise are narrow and worth the two minutes:

• Row 4 staying non-zero quarter after quarter, which is a backlog rather than a flow.
• Row 4 rising while row 2 is flat, which is disposal falling behind receipt.
• A missing filing, which carries its own thousand rupee a day fine and shows up in the exchange's non-compliance list rather than in the company's numbers.

None of it is a view on the business, and none of it is advice. It is a servicing metric, filed on a date, by the company itself.

So checking an investor complaint record is four numbers, read across quarters rather than inside one. A persistent row 4 is the signal; a single quarter's volume rarely is.

Flock reports the filings themselves, each one dated and linked to its source. What any disclosure means for your money is your call to make. Not investment advice.