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Yes, you can report an unregistered investment scheme to SEBI, but an ordinary SCORES complaint is usually not the correct route. SEBI’s SCORES FAQ excludes complaints about “any unregistered/ un-regulated activity.” For an alleged unregistered Collective Investment Scheme (CIS), SEBI’s CIS FAQ directs investors to send a written complaint by post to a SEBI office. SEBI may then examine the arrangement under Section 11AA of the SEBI Act, 1992 and the SEBI (Collective Investment Schemes) Regulations, 1999.
Your best first steps are to preserve every document, describe how money was collected and managed, mail a specific complaint with supporting evidence, and keep proof of delivery. SEBI’s process is not a private-court judgment and does not guarantee that your money will be recovered.
What counts as an unregistered-scheme complaint?
The label used by a promoter is not decisive. An arrangement may warrant examination as a CIS when investors’ money is pooled, a person or company manages the pooled funds or property, investors expect profits, returns or other benefits, and they do not control the day-to-day management themselves. Whether those elements exist is a fact-specific legal question.
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Why you should not use ordinary SCORES for an unregistered operator
SCORES is designed for grievances against entities regulated by SEBI. SEBI’s SCORES FAQ expressly says that “Complaints about any unregistered/ un-regulated activity” are not treated as SCORES complaints. A complaint about an unregistered company, informal investment pool or other unregulated activity can therefore be rejected or excluded if filed as though the operator were a registered intermediary.
This is different from a grievance against a registered Collective Investment Management Company (CIMC). A registered CIMC has a regulated grievance process, while an unregistered operator does not have the same SCORES escalation path. Choosing the correct route at the beginning avoids losing time and preserves a clear record of what you asked SEBI to examine.
The correct route for an alleged unregistered CIS
SEBI’s CIS FAQ says: “With regard to unregistered Collective Investment Schemes: Investors may send their complaint by post to any of the SEBI offices…” Use the office addresses listed in SEBI’s current investor and CIS contact information, and verify the address before mailing.
- Prepare a signed written complaint. Give your full name and contact details, then identify the operator, promoter, agent and scheme as precisely as possible.
- Describe the transaction chronologically. Include when you were approached, what documents or advertisements you received, the amounts and dates paid, the promised return or benefit, and what happened when payment or redemption was due.
- Attach an indexed evidence bundle. Number the attachments and refer to those numbers in the narrative so an investigator can match each allegation to a document.
- Mail the complaint to a SEBI office. Use a trackable postal service and retain the receipt, tracking record and a complete copy of everything sent.
- Ask how the submission is recorded. Keep any acknowledgement, reference number or request for additional information. If SEBI asks for clarification, answer in writing and retain that response.
- Report urgent or continuing conduct separately where appropriate. If the information is primarily an allegation of securities-law violations rather than your own redress request, SEBI may direct it to the Market Intelligence Portal as confidential market intelligence.
The postal route is an examination channel, not a promise that the operator will be ordered to repay you. SEBI’s CIS FAQ links the examination of an unregistered CIS to Section 11AA of the SEBI Act and the CIS Regulations, 1999.
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Evidence to preserve before you complain
Make a secure, read-only copy of your records before contacting the promoter. Do not rely on a website or messaging account remaining available. SEBI’s SCORES FAQ excludes incomplete or unspecified complaints and allegations that lack supporting documents; the same discipline is important for a postal submission.
- Offer documents, brochures, application forms, certificates, passbooks and agreements.
- Advertisements, social-media posts, presentations and screenshots showing promised returns, guarantees or benefits.
- Receipts, invoices, bank statements, cancelled cheques and UPI, wallet or other transfer records.
- Emails, text messages, chat exports, call details and letters exchanged with the operator or agents.
- The legal names, trading names, addresses, phone numbers, email addresses and bank-account details used by promoters or collecting agents.
- A schedule of every payment, including date, amount, payment method and transaction reference.
- Requests for withdrawal or repayment, the response received, and the amount still outstanding.
- Names and contact details of other investors who may independently hold relevant records.
Keep originals where possible. Send copies unless SEBI specifically requests an original, and redact unrelated personal information belonging to other people.
How to write the factual narrative
A useful complaint lets a reader who knows nothing about the scheme reconstruct the transaction. Start with a one-paragraph summary, then use dated headings or a table for the details. Include:
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- Pooling: whether money from multiple people was collected into a common project, account, asset or business.
- Management: who selected investments, operated the project, controlled bank accounts or made distribution decisions.
- Consideration: the return, profit share, interest, asset allocation, membership benefit or other advantage promised.
- Your loss or pending obligation: total paid, amounts received, maturity or withdrawal date, and the balance not returned.
- Current conduct: missed payments, changed contact details, new solicitations, pressure to reinvest or instructions to pay a different account.
Distinguish what you personally saw from what another investor told you. Mark estimates as estimates and identify the document supporting each material figure. Avoid conclusions that the evidence cannot establish; ask SEBI to examine whether the facts constitute an unregistered CIS or another securities-law violation.
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Registered CIMC, unregistered operator and information report: the routes compared
| Situation | Who is regulated | Submission channel | What SEBI’s process does | Time rule stated in the guidance | Possible next step |
|---|---|---|---|---|---|
| Grievance against a registered CIMC | A SEBI-registered Collective Investment Management Company | First approach the CIMC; if unresolved, use SCORES | Facilitates grievance redressal; it does not adjudicate the private dispute | The CIMC should take adequate steps within one month; SCORES windows apply after an eligible complaint is lodged | Review options, Online Dispute Resolution (ODR), consumer court or another appropriate civil remedy |
| Alleged unregistered CIS | No registered CIMC or other regulated entity has been established | Written complaint by post to a SEBI office | May examine the facts under Section 11AA and the CIS Regulations | No equivalent unregistered-CIS service-level promise is stated | ODR, consumer court or civil action may be considered separately, depending on the facts |
| Information about possible securities-law violations | May concern an unregistered or regulated actor | SEBI’s Market Intelligence Portal may be the appropriate information channel | Can be handled as confidential market intelligence rather than a SCORES grievance | No SCORES grievance timetable should be assumed | Preserve evidence and pursue any personal claim through an appropriate forum |
The one-month statement in the first row concerns a registered CIMC. It should not be presented as a deadline imposed on an unregistered promoter.
When SCORES does apply: the 2.0 timelines
If your matter concerns a SEBI-regulated entity and satisfies SCORES requirements, SEBI’s investor guidance describes these stages:
- Action Taken Report: the concerned entity generally has 21 calendar days to submit its response.
- First-level review: you generally have 15 days to seek a review of the response.
- Second-level review: a further 15-day window is available for review by SEBI.
The guidance also says a complaint should generally be lodged within one year of the cause of action. These periods do not turn an unregistered-scheme report into an ordinary SCORES complaint. If the operator is unregistered or the activity is otherwise outside SCORES’ scope, use the postal examination route described above instead.
What SEBI can and cannot decide
SCORES is a facilitative platform. SEBI states that it “does not adjudicate disputes between the complainant and the entity.” In practical terms, a response through SCORES is not the same as a civil-court judgment on liability, a determination of the amount owed, or an enforceable order resolving every disputed fact.
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For an unregistered CIS, SEBI may examine whether the arrangement falls within the statutory definition and whether securities-law action is warranted. The available material does not establish a scheme-specific recovery rate or guarantee that an investor will receive money back. Do not describe a postal complaint as an assured recovery mechanism.
Recovery and other remedies
Keep your SEBI complaint separate from steps aimed at recovering a private debt or investment. Depending on the contract, representations, payment records and parties involved, an investor may consider:
- Online Dispute Resolution: where the dispute and parties are eligible for that process.
- Consumer proceedings: where the transaction and respondent fall within consumer-law requirements.
- Civil action: for contractual, restitutionary or other claims recognised by the appropriate court.
These options have different limitation periods, jurisdiction rules and evidence requirements. A SEBI submission does not automatically pause those deadlines. Obtain qualified legal advice promptly if a substantial amount or a limitation issue is involved.
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A practical complaint format
Use a clear subject line such as “Complaint regarding suspected unregistered Collective Investment Scheme.” The following structure keeps the submission specific without assuming the legal conclusion:
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- Complainant details: name, address, phone number and email.
- Operator details: legal and trading names, addresses, promoters, agents and account details.
- Scheme description: what was offered, how investors paid, how funds were pooled and what return or benefit was represented.
- Chronology: dated events from solicitation through payment, maturity, withdrawal request and non-payment.
- Amounts: a payment table showing date, amount, method, reference number, amount received and balance claimed.
- Why examination is requested: explain the pooling, management and promised consideration, and ask SEBI to examine the arrangement under Section 11AA and the CIS Regulations.
- Attachments: an indexed list of every document, with copies enclosed.
- Declaration and signature: confirm that the account is based on your records and identify any point that is based on information from another person.
Send one coherent package rather than multiple messages containing different versions of the facts. If more than one investor complains, each person should preserve an individual payment schedule and personal statement even when the underlying scheme is the same.
Common mistakes that weaken a submission
- Filing an unregistered-operator complaint on SCORES and assuming it will receive the regulated-entity workflow.
- Using only labels such as “Ponzi” without explaining pooling, management, promised consideration and payment history.
- Sending screenshots without dates, transaction references or the surrounding conversation.
- Leaving out the operator’s legal name, address, bank details or agent identities when those details are available.
- Mailing originals without retaining a copy or proof of delivery.
- Assuming the one-month registered-CIMC grievance period applies to an unregistered promoter.
- Treating a SEBI acknowledgement or facilitation response as a guaranteed repayment order.
- Waiting to complain while continuing to send money or while evidence disappears.
Contact and follow-up
SEBI’s SCORES FAQ lists the toll-free numbers 1800 266 7575 and 1800 22 7575. They are listed as available from 9:00 a.m. to 6:00 p.m. on non-holiday days. Use them to clarify procedural questions, but do not treat a call as a substitute for the signed postal complaint and evidence bundle required for an alleged unregistered CIS.
After mailing, retain the postal receipt, delivery confirmation, final complaint PDF or photocopy, attachment index and a log of every follow-up. If SEBI requests more information, reply with the reference number and send only the additional material requested. Keep pursuing any separate civil, consumer or ODR option within its own deadline.
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