How to complain to a debenture trustee

How to complain to a debenture trustee has a defined route, a required set of details, and two different published time limits that do not match. The trustee has to publish a dedicated grievance email ID, publish its own complaint statistics monthly, and escalate to the issuer within a week where the issue is the issuer's. This guide covers the route, the details to include, the timelines, and the escalation path to SEBI. It is not investment advice.

Whose problem is it in the first place?

The issuer's. Chapter IX of SEBI's Master Circular for Debenture Trustees, SEBI/HO/DDHS-PoD-1/P/CIR/2025/117 dated August 13, 2025, opens by stating that the primary obligation on resolution of complaints is that of the issuer, and that the dispute resolution mechanism administered by stock exchanges covers such listed companies and the holders of debt securities.

That is worth knowing before you write anything, because it shapes where a complaint ends up. The trustee is a channel and a monitor, and the Investor Charter lists lodging complaints with the debenture trustee as an investor right. But on many issues the substantive answer has to come from the issuer, and the trustee's job is to get it there.

Paragraph 6.5 puts a clock on that handoff. Where a complaint needs to be escalated to the issuer by the debenture trustee, it shall be escalated within seven days of receipt of the complaint.

Where do you send the complaint?

To the address the trustee is required to publish. Paragraph 2 of Chapter IX requires a debenture trustee to designate an email ID of the grievance redress division or compliance officer exclusively for registering investor complaints, and to display that email ID and other relevant details prominently on its website and in the materials, pamphlets and advertisement campaigns it uses for investor awareness.

The Investor Charter adds the practical steps. Under paragraph 6.2, an investor can write to the trustee's dedicated grievance email IDs, or send a letter, or lodge the complaint directly on the link the trustee provides on its website.

Include six things. Paragraph 6.3 lists them:

• Nature of complaint
• Name of the issuer company
• Holding details including ISIN
• Full name of the debenture holder
• PAN
• Correct email ID

The ISIN is the item most often left out and the one that matters most, because obligations around default are reckoned at the ISIN level rather than at the issuer level.

How long should redress take?

Two instruments give two numbers, and they are not the same. Note which one is the regulation.

Regulation 14B(1) was inserted by the SEBI (Facilitation of Grievance Redressal Mechanism) (Amendment) Regulations, 2023 with effect from August 18, 2023, and reads that the debenture trustee shall redress investor grievances promptly but not later than 21 calendar days from the date of receipt of the grievance, and in such manner as may be specified by the Board. Regulation 14B(2) allows SEBI to recognise a body corporate to handle and monitor the grievance redressal process.

Anyone quoting a single number for this should say which document it comes from. The shorter figure sits in the parent regulations, and the 30 day figures sit in circular timelines and in the SCORES process.

What does the escalation to SEBI look like?

Through SCORES, with its own rules about when a complaint is actually closed. Paragraph 6.6 provides that an investor who is not satisfied with the redress by the debenture trustee or the issuer can lodge the complaint on the SEBI Complaints Redress System at scores.gov.in, or use the dispute resolution mechanism specified by SEBI with respect to the issuer.

Four points from paragraph 3 govern what happens next:

1. A trustee to whom a complaint is forwarded through SCORES must take immediate efforts for resolution within 30 days, and keep the complainant informed of the action taken.
2. The action taken report and supporting documents must be uploaded electronically in SCORES. Action is not considered complete if they are not uploaded, and the complaint is then treated as pending.
3. A complaint is treated as resolved, disposed or closed only when SEBI disposes or closes it in SCORES. Filing an action taken report does not by itself mean the complaint is no longer pending.
4. Failure to file an action taken report within 30 days of receipt of the grievance is treated both as failure to furnish information to SEBI and as non-redress of the investor grievance.

Separately, Regulation 14A of the SEBI (Debenture Trustees) Regulations, 1993, inserted with effect from July 4, 2023, routes claims, differences or disputes between a debenture trustee and the body corporate that appointed it to a resolution mechanism including mediation, conciliation or arbitration. Regulation 14A(2) provides that no loss, damage or expenses incurred by the debenture trustee or that body corporate shall be met out of the trust property.

Can you check a trustee's complaint record before you need it?

Yes, and it is published monthly. Paragraph 1.4 of Chapter IX requires every registered debenture trustee to disclose on its website the data on complaints received against it, or in respect of debt securities issues it deals with, and their redress, latest by the seventh of the succeeding month, in the format at Annex-IXB.

That format is more informative than a headline count. It splits complaints by source, being directly from investors, from SEBI SCORES, from stock exchanges and from other sources. It reports the number pending for less than three months separately from those pending for more than three months, and it requires the average resolution time in days. It also carries month-wise data on a half yearly basis and a five year rolling trend of annual disposal.

Related reading

The published service standards a trustee commits to are covered in what is the debenture trustee investor charter, and the obligations behind them are in duties of a debenture trustee. Where a complaint concerns a missed payment, the definitions and timelines are in what is an event of default on a debt security and what happens to a defaulted bond after maturity. What a trustee must publish generally is listed in what must a debenture trustee disclose on its website.

Complaining to a debenture trustee is a documented process with published timelines and a public record of how well each trustee meets them. Flock reports what issuers and trustees disclose, with the source and the date attached. It is not investment advice.