Yes, you can report an unregistered investment scheme to SEBI, but an ordinary SCORES filing is usually not the 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 complaint by post to a SEBI office. SEBI says the facts may then be examined under Section 11AA of the SEBI Act, 1992 and the SEBI (Collective Investment Schemes) Regulations, 1999.
That process is different from a regulated-entity grievance. It does not promise that SEBI will decide a private dispute or recover your money. Your best first steps are to preserve every record, describe the arrangement precisely, use the postal route, and consider separate dispute remedies if funds remain unpaid.
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Choose the correct SEBI route first
The operator’s regulatory status determines how SEBI handles your submission. Use the following distinction before completing any online form.
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Outbyte PC Repair FREEClear out junk files and repair common Windows errorsFree Scan →Outbyte Driver Updater FREEScan for outdated or missing drivers - takes under a minuteDriver Scan →| Situation | Where to submit | What SEBI process applies | Important limit |
|---|---|---|---|
| Registered Collective Investment Management Company (CIMC) grievance | First approach the CIMC; use SCORES if the response is unsatisfactory | The CIMC is expected to take adequate steps within one month, after which SCORES can facilitate the grievance | This one-month statement applies to a registered CIMC, not an unregistered operator |
| Alleged unregistered Collective Investment Scheme | Send a written complaint by post to a SEBI office using the investor/CIS contact addresses | SEBI may examine the facts under Section 11AA and the CIS Regulations, 1999 | Ordinary SCORES excludes unregistered or unregulated activity |
| Information about a possible securities-law violation rather than a personal grievance | SEBI’s Market Intelligence Portal may be the appropriate channel | The information can be treated as confidential market intelligence | It is not processed as an ordinary SCORES grievance |
If you cannot establish that the operator is a registered intermediary, do not assume that the standard SCORES workflow will accept the matter. Explain the uncertainty in your letter and provide the facts that allow SEBI to classify the arrangement.
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Why registration status changes the complaint process
SCORES is designed to facilitate redressal of grievances against SEBI-regulated entities. SEBI’s FAQ expressly states that complaints about unregistered or unregulated activity are not treated as SCORES complaints. Filing the same allegation through the portal can therefore result in exclusion rather than a substantive examination under the CIS framework.
An unregistered arrangement may still resemble a CIS in the way it collects and manages money. The legal question is fact-dependent. Labels such as “membership,” “advance purchase,” “land booking,” “trading pool” or “investment club” do not by themselves determine the classification. Your submission should show what the arrangement actually did: how money was pooled, who controlled it, what management or investment activity was promised, whether participants had day-to-day control, and what return, benefit or other consideration was represented.
Prepare the evidence before writing to SEBI
SEBI’s SCORES FAQ excludes incomplete or unspecified complaints and allegations without supporting documents. Although an unregistered-CIS complaint is sent by post rather than handled as a normal SCORES case, the same practical lesson applies: a precise, documented account is far more useful than a general accusation.
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- Offer documents, brochures, application forms, certificates, membership forms and agreements.
- Receipts, invoices, account statements and any schedule showing instalments or maturity dates.
- Bank statements, cancelled cheques, UPI confirmations, wallet records and transfer references.
- Advertisements, websites, social-media posts, presentations and recorded promises about returns or benefits.
- Emails, text messages, messaging-app conversations and call details with promoters or agents.
- The legal names, trading names, office addresses, phone numbers and payment details of the operator and its representatives.
Keep the originals safe and make an indexed copy for SEBI. Do not edit screenshots or crop away dates, account numbers or sender details. If a web page may disappear, save a dated PDF or screenshot and note the address at which it appeared.
Build a transaction chronology
Write a short timeline from the first solicitation to the present. Include the date and amount of every payment, the account or UPI identifier used, the benefit or return promised, any maturity or withdrawal request, and the response you received. State exactly what remains unpaid. If several investors are involved, identify your own transactions separately and attach a schedule rather than submitting an undifferentiated total.
How to send an unregistered-CIS complaint by post
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 investor and CIS contact information; do not substitute an unverified address copied from an old social-media post.
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- Address the complaint to SEBI. Put “Complaint regarding alleged unregistered Collective Investment Scheme” in the subject line and identify the SEBI office receiving it.
- Identify the parties. Give the operator’s legal and public names, scheme name, principal and branch addresses, website or social handles, promoters, agents and every payment account you know.
- Explain the arrangement. Describe how investors were recruited, how funds were collected or pooled, who managed them, what activity was promised and what return, asset, service or other consideration was represented.
- Set out your loss or outstanding claim. List each payment, the promised due date or exit condition, amounts received, amounts due and dates on which you demanded repayment or performance.
- Attach an indexed evidence bundle. Number each attachment and refer to it in the narrative. Include copies rather than irreplaceable originals.
- Sign and provide contact details. Include your postal address, email address and telephone number so SEBI can seek clarification.
- Use a trackable postal service. Keep the receipt, delivery confirmation, a complete copy of the letter and a list of attachments.
- Ask how the submission is recorded. Request an acknowledgement or reference number and retain any subsequent correspondence.
There is no SCORES-style service-level promise in the cited CIS guidance for an unregistered operator. Do not describe the 21-day SCORES response period as a deadline that applies to this postal examination.
Give SEBI facts relevant to Section 11AA
The CIS FAQ links an unregistered-CIS complaint to examination under Section 11AA of the SEBI Act, 1992 and the CIS Regulations, 1999. SEBI will need facts, not merely a conclusion that the promoter ran a “Ponzi scheme.” Organise the letter around the features that help distinguish a collective investment arrangement from an ordinary sale, loan or service contract.
Pooling of money
State whether money from multiple people was collected into a common project, account or asset. Explain whether your payment was pooled with other participants’ contributions and whether the promoter used a standard payment schedule or common fund.
Management or investment activity
Identify what the operator said it would do with the money: acquire or develop property, trade securities, operate a business, buy commodities, or provide another managed opportunity. Include the documents and statements describing that activity.
Control and participation
Explain who made decisions and whether investors had any day-to-day control over the property, business or investments. A statement that participants had no practical role can be important, but do not infer the legal result yourself; provide the underlying facts.
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Return or other consideration
Record the promised yield, profit share, buy-back, appreciation, periodic payout, service or asset. Distinguish a contractual promise from a payment actually received and identify every changed promise or revised maturity date.
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When the registered-CIMC and SCORES process applies
A different path applies when the complaint concerns a registered Collective Investment Management Company. SEBI’s CIS FAQ says the investor should first approach that CIMC. The company must take adequate steps to redress the grievance within one month. If the response is absent or unsatisfactory, the matter can then be taken to SCORES.
This sequence matters because SCORES is a facilitative escalation mechanism for regulated entities, not a substitute for identifying an unregistered promoter. Check the entity’s regulatory identity in your documents and state what response you received from it before escalating.
How SCORES 2.0 timelines work—and what they do not mean
For a complaint that is within SCORES’ regulated-entity scope, SEBI’s investor guidance describes the following windows:
| Stage | Stated period | What it covers |
|---|---|---|
| Action Taken Report by the concerned entity | 21 calendar days | The regulated entity records the action taken on the complaint |
| First-level review | 15 days | The complainant can seek the first review within the stated window |
| Second-level review by SEBI | Further 15 days | A second review is available under the SCORES process |
| General filing expectation | Usually within one year of the cause of action | SEBI’s guidance says complaints should generally be lodged within this period |
These periods are process windows, not a guarantee that an investor will receive payment. More importantly, they do not convert an unregistered-scheme report into an ordinary SCORES complaint. The postal CIS route has no equivalent published SCORES deadline in the cited guidance.
Separate a personal grievance from market intelligence
A personal grievance asks SEBI to consider what happened to you: the payments you made, the promised benefit, the default and the documents proving it. Information about a suspected securities-law violation may instead be useful as confidential market intelligence. SEBI’s FAQ indicates that such information can be directed to the Market Intelligence Portal rather than processed as a SCORES grievance.
If you are submitting both, label them separately. In the postal complaint, request examination of your alleged unregistered CIS facts and identify your evidence. In a market-intelligence submission, explain the broader conduct, the people or entities involved and why it may affect other investors. Avoid assuming that a confidential intelligence report will produce an individual repayment decision.
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What SEBI can and cannot do
SEBI’s SCORES FAQ describes the platform as “a facilitator of redressal of complainant’s grievance from SEBI regulated entities” and says it “does not adjudicate disputes between the complainant and the entity.” That limitation is important even when the underlying conduct appears serious.
- SEBI can receive and examine information under its statutory and regulatory powers.
- For a registered entity within SCORES, the platform can facilitate a response and review of the action taken.
- For an alleged unregistered CIS, SEBI can assess whether the facts warrant examination under Section 11AA and the CIS Regulations.
- SEBI does not act as a private court that determines every disputed contract, awards damages or guarantees recovery.
- No authoritative scheme-specific recovery rate or success rate is established for unregistered investment schemes.
Do not promise yourself or other investors that a SEBI filing will return the principal. Treat the regulatory submission and the pursuit of a private remedy as separate decisions.
If money is still owed, consider other remedies
SEBI’s FAQ identifies Online Dispute Resolution, consumer courts or other appropriate civil remedies for a complainant dissatisfied with the outcome of a facilitative process. Which option fits depends on the contract, the parties, the amount, limitation rules and the nature of the transaction. Preserve the same evidence bundle for any forum and obtain advice on jurisdiction and deadlines before filing.
An ODR or court process is not a replacement for accurately reporting an alleged unregistered CIS. Conversely, sending a complaint to SEBI does not pause every limitation period or automatically commence a recovery action. Keep a record of demand letters, acknowledgements and dates on which money became due.
Common mistakes and how to fix them
Submitting an unregistered complaint only through SCORES
Problem: The SCORES FAQ excludes unregistered or unregulated activity.
Fix: Use the postal SEBI route for an alleged unregistered CIS and explain the facts supporting that description.
Sending a conclusion without documents
Problem: “Fraud” or “Ponzi” labels do not show who received money, when it was paid or what was promised.
Fix: Attach payment proof, agreements, promotional material and a dated chronology.
Using the registered-CIMC one-month period as a promise
Problem: The one-month redressal statement concerns a registered CIMC.
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Fix: Do not impose that deadline on an unregistered operator or assume a postal examination has a fixed completion date.
Asking SEBI to decide a private contract
Problem: SCORES facilitates grievance handling but does not adjudicate disputes.
Fix: State the regulatory facts clearly and evaluate ODR, consumer or civil remedies separately if recovery is the goal.
Leaving out the operator’s identity or payment trail
Problem: SEBI may be unable to connect a scheme name to a legal entity or transaction account.
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Final mailing checklist
- Operator and scheme names are spelled consistently.
- Every payment is listed with date, amount and channel.
- Promised returns, benefits and due dates are quoted or accurately paraphrased.
- Unpaid amounts and repayment requests are clearly separated from amounts already received.
- Attachments are legible, numbered and cross-referenced.
- The letter explains pooling, management, investor control and promised consideration where those facts exist.
- The complaint is addressed to a SEBI office listed in current investor/CIS contacts.
- A complete copy, postal receipt and delivery proof are retained.
- Any separate market-intelligence information is labelled as such.
- You understand that SEBI examination is not a guaranteed recovery or private judgment.
SEBI contact help for SCORES questions
SEBI’s SCORES FAQ lists the toll-free numbers 1800 266 7575 and 1800 22 7575, available from 9:00 a.m. to 6:00 p.m. on non-holiday days. These numbers can help with platform or process questions, but the FAQ’s exclusion for unregistered or unregulated activity remains controlling. For an alleged unregistered CIS, keep the postal complaint and its delivery evidence as your primary submission record.
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