SEBI ODR Direct Conciliation from SCORES: Investor-to-Intermediary Workflow
By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026
SEBI's 23 July 2026 paper proposes streamlining ODR, including a more direct conciliation path from the investor grievance ecosystem. The proposed flow must be distinguished from the already-operative ODR master circular.
Finin2min 2-Minute Summary
- The 2023 ODR master circular is the operative base framework.
- SEBI issued a 23 July 2026 consultation paper proposing further streamlining of ODR.
- Any 'direct conciliation from SCORES' feature described in that paper should be labelled proposal unless a later operative circular is verified.
- Investors should maintain one evidence bundle that can move from grievance to conciliation without changing the factual chronology.
- Regulated entities should route ODR cases to an authorised team with settlement limits and document access.
Current framework vs July proposal
Do not describe the consultation as an already-live button or mandatory process. The current master circular remains the legal starting point, while the July paper indicates how SEBI may simplify hand-off and conciliation.
Before publishing a procedural screenshot, verify the actual SCORES/ODR portal behaviour because platform features can change after a regulatory proposal.
Prepare the dispute before conciliation
Write a statement of facts, disputed amount/security, documents, prior ATRs and the exact settlement outcome sought. Conciliation works better when the parties are arguing about a defined issue rather than an entire account relationship.
Keep claim calculations simple enough that the intermediary can reproduce them.
Entity-side governance
The intermediary should know who can attend, who can make a settlement offer, what records can be disclosed and when counsel/compliance must be involved. A representative with no authority turns conciliation into another delay.
Log offers and reasons without treating a conciliation discussion as an admission beyond the applicable process.
Conciliation case: both sides agree on trades but disagree on loss
An investor and intermediary may agree that a technology outage occurred yet disagree on whether the investor's claimed loss was caused by it. Before conciliation, separate uncontested facts from disputed causation. List affected orders, timestamps, exchange status, alternative channels, subsequent trades and the calculation of claimed loss.
The intermediary should bring system logs and the investor should bring broker/exchange statements rather than screenshots alone. A conciliation session is more productive when the parties can focus on the economic consequence rather than spend the entire meeting reconstructing basic events.
- Create an agreed-facts section before the disputed issues.
- Use exchange/broker records for order status.
- Show the loss formula and assumptions transparently.
Outcome documentation
At the end of conciliation, record precisely what was agreed, what remains disputed, payment or operational deadlines and who will confirm completion. A verbal 'resolved' status is not enough if securities, money or records still have to move after the session.
- Translate agreement into dated actions.
- Verify completion before marking the dispute closed.
ODR transition pack
- Operative ODR source verified.
- July 2026 proposal labelled as proposal.
- SCORES chronology exported.
- Loss/remedy calculation.
- Core documentary exhibits.
- Authorised entity representative.
- Conciliation outcome and next route recorded.
Questions readers commonly ask
Is SEBI's July 2026 ODR paper final?
No. It is a consultation paper.
Does ODR already exist?
Yes. The current ODR master circular predates the July 2026 proposal.
What is the key investor preparation?
A concise chronology and exact remedy supported by documents.
Can a portal change make the consultation automatically law?
No. Verify the operative circular/regulatory instrument.
Official / primary sources
- SEBI ODR Master Circular - Current operative framework
- SEBI ODR Streamlining Consultation - 23 July 2026 proposal
Disclaimer
Important: General educational and professional-reference material. Verify the current operative regulation/circular, portal version and exact facts before acting. Consultation papers are proposals unless a later operative instrument adopts them. Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.