Investing through a Portfolio Management Service (PMS) or Alternative Investment Fund (AIF) comes with a higher level of documentation, contractual terms and regulatory requirements. That also means investors have defined channels to raise concerns when something goes wrong.
A complaint against PMS may relate to issues such as incorrect charges, reporting discrepancies, failure to follow agreed terms, unauthorised transactions, delayed responses, inadequate disclosures or other service-related concerns. Similarly, a Complaint against AIF may involve matters concerning fund documentation, reporting, fees, distributions, disclosures, transactions or the conduct of the fund, manager or sponsor.
The important point is to use the right channel for the nature of the issue.
For most investors, the process broadly starts with the concerned PMS, portfolio manager, AIF or fund manager. If the matter is not resolved satisfactorily, SEBI's SCORES platform can provide a formal grievance escalation route for eligible securities-market complaints. Where the matter is a dispute requiring conciliation or arbitration, the Online Dispute Resolution (ODR) mechanism can provide another route.
This guide explains how the process works, what documents to keep and what investors should realistically expect from SCORES and ODR.
When Can an Investor Raise a Complaint Against an AIF or PMS?
An investor does not have to wait for a major financial loss before raising a grievance.
A complaint against PMS can arise when an investor believes that the portfolio manager has not addressed a legitimate service or regulatory concern. Examples may include:
- Incorrect or unexplained fees or charges
- Discrepancies in portfolio statements
- Missing or delayed reports
- Concerns about transactions carried out in the portfolio
- Failure to provide information required under applicable regulations or agreements
- Concerns regarding disclosures or communication
- Issues relating to redemption, withdrawal or termination, where applicable
- Failure to respond to a previously raised grievance
- Any other issue that falls within the applicable regulatory or contractual framework
For AIF investors, an AIF investor grievance may involve:
- Incorrect reporting of fund-level information
- Questions concerning fees, expenses or distributions
- Delays in providing investor information
- Concerns regarding disclosures
- Issues involving the terms contained in fund documents
- Questions regarding capital calls or distributions
- Concerns about transactions or processes that affect the investor
- Failure to respond to a grievance raised with the AIF, manager or sponsor
A Complaint against AIF should be framed around specific facts, documents and the action expected from the concerned entity. A general statement such as "the fund performed badly" is different from a grievance alleging that a contractual or regulatory obligation was not followed.
Likewise, a complaint against PMS should identify the specific transaction, communication, charge, document or event giving rise to the grievance.
How to Raise a Complaint With an AIF or Portfolio Manager
The first step in a complaint against PMS is generally to approach the portfolio manager directly through its designated grievance or compliance channel.
The same principle applies to an AIF investor grievance. Investors should first approach the concerned AIF, fund manager or other designated grievance contact specified in the fund documentation.
Step 1: Identify the exact issue
Before writing the complaint, establish:
- What happened?
- When did it happen?
- Which transaction, statement or document is involved?
- What contractual or regulatory requirement do you believe is relevant?
- What resolution are you seeking?
This makes a complaint against PMS easier to investigate and reduces unnecessary back-and-forth.
Step 2: Put the complaint in writing
Use email, the entity's investor grievance portal or another official channel provided by the regulated entity.
Keep the communication factual.
Instead of writing:
"My portfolio has been handled badly."
write:
"The portfolio statement dated [date] shows a charge of ₹X. I could not reconcile this charge with the fee schedule in the agreement. Please provide the calculation and supporting basis for the charge."
That creates a clearer record.
Step 3: Attach supporting documents
A strong complaint against PMS should be supported by relevant records rather than assumptions.
Useful documents may include:
- PMS agreement
- AIF subscription or contribution documents
- Private Placement Memorandum, where relevant
- Account statements
- Portfolio statements
- Transaction statements
- Fee statements
- Capital call notices
- Distribution statements
- Emails and correspondence
- Screenshots of relevant communications
- Bank records, where directly relevant
- Previous complaint and response
Step 4: Keep proof of submission
Save the complaint, attachments and acknowledgement.
If you later need to file a SCORES PMS complaint, these records can help demonstrate that you first approached the concerned entity.
For an AIF complaint process, the same documentation becomes important if the issue progresses to SEBI or ODR.
How to File a Complaint Through SEBI SCORES
SEBI's SCORES platform is an online grievance redressal facilitation mechanism for eligible securities-market complaints against listed companies, SEBI-registered intermediaries and other entities covered by the platform.
A SEBI SCORES complaint is not the same thing as filing a lawsuit. SCORES facilitates the grievance process and enables the concerned entity to provide an Action Taken Report (ATR).
Investors should generally first approach the concerned entity before escalating to SCORES.
What SCORES Covers
A SCORES PMS complaint can be relevant when the grievance concerns a SEBI-regulated portfolio manager and falls within the scope of matters that can be handled through SCORES.
An SCORES AIF complaint may similarly be relevant for eligible complaints concerning an AIF or its regulated ecosystem.
SCORES is designed for securities-market grievances covered by the applicable SEBI framework.
However, not every disagreement qualifies.
SEBI's SCORES FAQs state that matters such as anonymous complaints, incomplete or non-specific complaints, complaints outside the securities market and allegations without supporting documents may not be considered.
That distinction matters.
A complaint against PMS should therefore be specific, documented and connected to an issue that falls within the applicable regulatory framework.
How to File a Complaint Step by Step
1. Register or log in to SCORES
Use the official SEBI SCORES platform.
2. Select the relevant category
Identify the regulated entity and the category that most closely matches the issue.
3. Explain the grievance clearly
Include:
- Name of the entity
- Relevant account or client reference
- Date of the issue
- Nature of the grievance
- Earlier communication with the entity
- Response received, if any
- Specific resolution being sought
4. Upload supporting documents
Attach only relevant documents. Avoid submitting large quantities of unrelated information.
5. Submit and save the complaint number
The complaint reference number is important for tracking the case.
6. Monitor the response
The concerned entity submits an Action Taken Report through the SCORES system.
If the response does not address the grievance adequately, the investor should use the review option within the prescribed time.
SCORES Timelines and Review Levels
SCORES 2.0 introduced defined timelines and a two-level review mechanism.
| Stage | What happens | Investor timeline |
| Initial complaint | Complaint is routed to the concerned entity | Entity has 21 calendar days to submit its Action Taken Report |
| First-level review | Investor can request review if dissatisfied with the entity's response | Within 15 calendar days of receiving the ATR |
| Designated Body review | Designated Body examines the matter and provides an ATR | As per the applicable SCORES process |
| Second-level review | Investor can request another review if dissatisfied with the first-level response | Within 15 calendar days of receiving the first-level ATR |
| SEBI review | SEBI takes up the matter at the second review level | As per the applicable process |
| ODR option | Investor may opt for Online Dispute Resolution | SCORES complaint is treated as disposed when the investor opts for ODR |
The 15-day review windows are important. An investor should not assume that a complaint will remain open indefinitely after an ATR is submitted.
SCORES data published by SEBI explains that complaints are automatically routed to the concerned entity, which has 21 days to submit its ATR. If the investor remains dissatisfied, first-level review can be requested within 15 days. A further 15-day window applies after the Designated Body's ATR for second-level review.
What Is Online Dispute Resolution (ODR)?
ODR for investors refers to Online Dispute Resolution, a technology-enabled mechanism for resolving eligible securities-market disputes through processes such as pre-conciliation, conciliation and arbitration.
SEBI's investor information identifies AIF fund managers and Portfolio Managers among the securities-market entities against whom eligible investors may invoke the ODR process.
This makes SMART ODR securities market an important option to understand when a grievance becomes a substantive dispute.
The distinction between SCORES and ODR is important.
SCORES is primarily a grievance redressal facilitation mechanism.
ODR is a dispute-resolution mechanism that can involve conciliation and, where applicable, arbitration.
In an arbitration proceeding, the arbitrator can adjudicate the dispute within the scope of the applicable framework.
How Does SMART ODR Work?
The ODR for investors process generally begins with the investor approaching the concerned intermediary or regulated entity.
The broad flow is:
Investor raises grievance → Entity response → ODR registration → Pre-conciliation → Conciliation → Arbitration, where applicable
Pre-conciliation
The ODR process can first attempt to facilitate an amicable resolution.
Conciliation
If the matter is not resolved, it can proceed to conciliation through an appointed conciliator.
The framework provides for a conciliation period of 21 days, which may be extended by 10 days with the consent of the parties.
Arbitration
If conciliation does not resolve the matter, the investor may request arbitration where applicable.
The arbitration process is generally to be concluded within 30 days, with the framework providing for an extension of 30 days.
Investors should check the current ODR framework and applicable fee structure before filing because SEBI has also issued a consultation paper in July 2026 proposing changes to streamline the ODR framework.
SCORES vs ODR: What Is the Difference?
| Point | SCORES | ODR |
| Primary purpose | Facilitate grievance redressal | Resolve eligible disputes |
| Managed through | SEBI's SCORES framework | SMART ODR ecosystem |
| Initial approach | Investor generally first approaches the entity | Investor must first approach the intermediary/entity |
| Entity response | Action Taken Report | Pre-conciliation and dispute-resolution process |
| Review | Two levels of review | Conciliation and potentially arbitration |
| Arbitration | No | Yes, where applicable |
| Compensation or specific dispute resolution | SCORES is not an adjudicatory forum for third-party rights | ODR can provide a dispute-resolution route, including arbitration |
| Best suited to | Regulatory/service grievance | A dispute requiring structured resolution |
A PMS dispute resolution matter may therefore move beyond a normal grievance if the investor and portfolio manager remain in disagreement over an issue that requires adjudication.
Similarly, AIF dispute resolution may involve contractual dispute-resolution provisions contained in the fund documentation.
How Does the AIF and PMS Grievance Process Work?
A practical PMS grievance redressal process can be viewed as a series of stages.
Stage 1: Raise the issue with the concerned entity
For a complaint against PMS, approach the portfolio manager.
For a Complaint against AIF, approach the AIF, fund manager or designated grievance contact.
Stage 2: Give the entity an opportunity to respond
Keep the communication trail.
The response may resolve the issue, partially address it or leave the investor dissatisfied.
Stage 3: Escalate to SCORES where applicable
A SEBI investor complaint can be lodged through SCORES when the matter falls within its scope.
Stage 4: Use review options
If the response is inadequate, use the prescribed first- and second-level review windows.
Stage 5: Consider ODR for an eligible dispute
If the matter requires dispute resolution rather than only regulatory grievance facilitation, SMART ODR may be relevant.
For an AIF complaint process, investors should also read the dispute-resolution clause in the applicable fund documents. AIF documents may specify mechanisms such as arbitration or other procedures mutually agreed between the parties.
What Documents Should Investors Keep?
Documentation can make or break the clarity of a grievance.
For a complaint against PMS, keep a dedicated folder containing:
- PMS agreement
- Disclosure document
- Portfolio statements
- Transaction statements
- Bank statements where relevant
- Fee and expense statements
- Emails and letters
- Screenshots of relevant communications
- Trade or transaction confirmations
- Complaints already submitted
- Responses received
- SCORES complaint reference and ATR
- ODR records, if applicable
For an AIF, also retain:
- Private Placement Memorandum
- Contribution agreement
- Capital call notices
- Distribution statements
- Valuation reports or statements supplied to investors
- Investor communications
- Fund reports
- Relevant notices from the manager
- Any amendments or side-letter documents applicable to the investor
For both PMS and AIF investments, do not edit or selectively remove information from the original record.
Maintain the original document and create a separate working copy if you need to annotate it.
What Can Investors Do If a Complaint Is Not Resolved?
If a complaint against PMS remains unresolved, the next step depends on the nature of the issue and the response received.
Possible routes include:
1. First-level SCORES review
If the investor is dissatisfied with the entity's ATR, the investor can request the prescribed first-level review within the applicable 15-day window.
2. Second-level SCORES review
If the investor remains dissatisfied after the Designated Body's response, the investor can request the second-level review within the prescribed period.
3. SMART ODR
For eligible disputes, the investor may consider the ODR mechanism.
4. Contractual dispute-resolution mechanism
Review the PMS agreement, AIF documents or other applicable contractual documents. They may contain specific provisions relating to arbitration or other dispute-resolution procedures.
5. Other legal remedies
Depending on the facts and the nature of the dispute, other remedies may be available under applicable law.
This is one area where investors should avoid assuming that every unresolved complaint against PMS automatically becomes a SEBI enforcement matter. The appropriate route depends on the issue.
What SCORES and ODR Cannot Do
Understanding the limitations is as important as knowing the process.
SCORES is not a court
SCORES is a grievance redressal facilitation mechanism. It is not a substitute for a court or an arbitral tribunal.
SCORES does not guarantee compensation
Filing a SEBI SCORES complaint does not automatically mean that an investor will receive compensation, reversal of losses or any specific financial outcome.
Investment losses alone are not automatically a regulatory violation
Markets involve risk. A fall in the value of an AIF or PMS portfolio does not, by itself, establish that the manager violated a regulation or contractual obligation.
An investor should distinguish between:
- Poor investment performance
- Disagreement with an investment decision
- A service deficiency
- A contractual dispute
- An alleged regulatory violation
These can require different approaches.
ODR is not a guarantee of settlement
Conciliation depends on the parties reaching an agreement.
Where arbitration is invoked, the process is governed by the applicable ODR and arbitration framework.
Not every complaint is eligible
Investors should verify whether the relevant entity and subject matter fall within the applicable SCORES or ODR framework.
Investor Complaint Checklist
Before filing a Portfolio manager complaint or AIF grievance, ask yourself:
- Have I identified the exact issue?
- Have I checked the relevant agreement or fund document?
- Have I approached the concerned entity first?
- Do I have written proof of my complaint?
- Have I received a response?
- Is my complaint supported by documents?
- Have I clearly stated the resolution I am seeking?
- If using SCORES, have I checked the applicable review deadline?
- If considering ODR, is the entity and dispute eligible?
- Have I checked the contractual dispute-resolution clause?
- Have I retained copies of all submissions and responses?
This checklist can prevent a common mistake: escalating a complaint without first creating a clear documentary record.
Complaint Against PMS vs Complaint Against AIF: What Changes?
The underlying process is similar, but the investment structures are different.
A PMS is a portfolio-management arrangement where a portfolio manager manages securities on behalf of the client under the applicable agreement and regulatory framework.
An AIF is a pooled investment vehicle with its own fund structure, manager, sponsor and governing documents.
Therefore, an AIF investor grievance may require investors to review several documents before deciding what exactly they are disputing.
For example, a question about a capital call should be examined against the relevant fund documentation. A question about a PMS charge should be checked against the PMS agreement and applicable fee disclosures.
In both cases, precision matters.
How to Write an Effective Complaint
A useful complaint can follow this format:
Subject: Investor Grievance - [Account/Fund Reference] - [Issue]
- Background:State when and through which entity you invested.
- Issue:Describe the specific event or discrepancy.
- Evidence:Mention the relevant statement, transaction, email or document.
- Previous communication:Mention when you first raised the issue and the response received.
- Resolution requested:State clearly what you want the entity to review, clarify, correct or provide.
- Supporting documents:Attach only relevant evidence.
This structure makes a complaint against PMS easier for the concerned team to understand and investigate.
It is equally useful when preparing an AIF complaint process submission.
Final Takeaway
A complaint against PMS should not begin with an emotional allegation. It should begin with a clearly identified issue, supporting evidence and a specific request for resolution.
The same approach applies to a Complaint against AIF.
For investors, the broad escalation path is:
Concern → AIF/PMS grievance channel → Response → SCORES, where applicable → Review → ODR or other appropriate remedy, where applicable
The key is knowing what you are actually disputing.
A portfolio loss is not automatically a regulatory grievance. A delayed response is different from an alleged breach of contract. A documentation issue is different from a dispute requiring arbitration.
For HNIs and other investors using PMS or AIF structures, maintaining complete records and understanding the applicable agreements can make the grievance process considerably clearer.
ALTPORT provides an information and access layer for investors exploring alternative investment products. It does not adjudicate disputes between investors and product issuers, Portfolio Managers, AIFs, fund managers or other regulated entities. Investors should independently review the relevant product documents and seek appropriate professional or legal advice where required.
Important: This article is for general information and investor education only. It is not legal, tax, investment or financial advice. ALTPORT is an APMI-registered investment platform/distributor and does not adjudicate investor disputes or act as an adviser to investors. Regulatory processes, timelines and applicable mechanisms may change. Investors should verify the latest requirements with SEBI and the concerned regulated entity before taking action.