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KYC Onboarding Spec by Rakesh Waghela

Deep Dive: ECN and investor-servicing artefacts

Why this page is structured this way: Investor-servicing artefacts — ECN, daily margin statement, quarterly statement of accounts, daily holding statement, annual P&L statement, Form 16A, investor charter — are produced on a clock and dispatched on prescribed channels with prescribed retention. The compliance reading they need is at the format level: which columns appear, which signature applies, which channel is mandated, how long the artefact must be retained, what happens on dispatch failure. This page captures that detail across the artefact set so a compliance officer or back-office engineer can validate the firm’s outputs against the regulator’s spec without cross-referencing five different circulars.

TL;DR

Section titled “TL;DR”
  • Electronic Contract Note (ECN) is the digitally signed trade-confirmation issued to a client for each trading day with activity. Format prescribed by NSE NSE/INSP/61999 (May 13, 2024 revision) with FAQ supplement in NSE/INSP/63859. ECN must be digitally signed under the IT Act 2000 by the broker’s Digital Signature Certificate (DSC) and dispatched within 24 hours of trade execution.
  • Two ECN format options under NSE/INSP/61999:
    • Annexure A — Contract Note Cum Tax Invoice (single combined document)
    • Annexure B — Separate Contract Note + Tax Invoice (two distinct documents)
  • Dispatch channels: email + SMS link via DLT-approved templates per NSE/INSP/52604 (June 2022). Both channels are preserved as evidence of dispatch.
  • Daily margin statement to clients per NSE/INSP/64315 (October 2024).
  • Quarterly statement of accounts per the running-account framework — covers trades, ledger, holdings, and the running-account settlement evidence. Settlement on first Friday and/or Saturday of the settlement week per SEBI Dec 2023 (SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2023/187).
  • Daily holding statement for active accounts via daily API submission to exchange and dispatch to client; standardised by NSE/INSP/55039.
  • Annual statement (P&L / Form 16A / capital gains) dispatched once at FY close.
  • Investor charter published on broker website per SEBI investor-protection framework and reinforced with SCORES 2.0 launch — see CDSL/IG/DP/GENRL/2024/593 and SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/0000013.
  • Retention period: 8 years for ECNs and most investor-servicing artefacts per SEBI books-and-records framework; longer for PMLA-relevant records (10 years). Default channel is electronic; physical dispatch on client opt-in.
  • AI-generated synthesis. Verify any specific column, channel, or retention period against the linked circulars before acting.

Conceptual overview

Section titled “Conceptual overview”

A broker’s relationship with a client is documented through a series of standardized artefacts — contract notes for individual trades, margin statements for daily margin position, quarterly statements for running-account settlement, annual statements for FY-close summary, and an investor charter for public-disclosure standards. Each artefact has a format (what columns / fields), a signature (digital under IT Act 2000), a dispatch channel (DLT-approved SMS + email), and a retention period (8 years for most, longer for PMLA-relevant). These are not just record-keeping niceties — they are evidence of broker conduct that surfaces in SEBI inspections, SCORES complaints, ODR proceedings, IGRC mediations, and dispute litigation.

The artefact framework has evolved with regulatory changes:

This page indexes each artefact, its format detail, dispatch / retention requirements, and the cross-link to upstream / downstream cycles.

Electronic Contract Note (ECN) — format detail

Section titled “Electronic Contract Note (ECN) — format detail”

Trigger and timing

Section titled “Trigger and timing”

The ECN is generated for every trading day on which a client transacted. Per INVESTOR-SERVICING-001 in the Compliance Blueprint, the ECN must be issued within 24 hours of trade execution — i.e., by T+1 noon at the latest, with most brokers dispatching on T-day evening. Late or non-dispatch attracts penalty per NSE/INSP/53530 and SCORES complaint exposure.

Format options under NSE/INSP/61999

Section titled “Format options under NSE/INSP/61999”

The May 13, 2024 NSE circular NSE/INSP/61999 revised the contract note format following SEBI master regulatory changes, superseding prior versions NSE/INSP/51772 (March 2022), NSE/INSP/45879 (September 2020), NSE/INSP/39158 (October 2018), and NSE/INSP/35036 (June 2017). Members opting for one of two formats:

  • Annexure A — Contract Note Cum Tax Invoice — a single combined document that serves both as the contract note and the tax invoice for GST purposes.
  • Annexure B — Separate Contract Note + Tax Invoice — two distinct documents (one as contract note, one as tax invoice), each with its own format.

The FAQ supplement NSE/INSP/63859 (September 10, 2024) clarifies optional vs mandatory fields, MTF treatment, and direct-payout-to-demat handling.

Mandatory columns / fields (Annexure A / B)

Section titled “Mandatory columns / fields (Annexure A / B)”

The columns mandated by the ICAI prescription (carried over and refined under NSE/INSP/61999 and the SEBI master) are the following. Specific column names may vary across exchanges (NSE / BSE / MCX) but the substance is consistent:

  1. Contract Note Number — unique per client per trading day, with broker-specific prefix and a sequential numeric tail.
  2. Trade Date — the date on which the trade(s) were executed.
  3. Settlement Type — T+1 default for cash; T+0 for opted T+0 trades; T+2 / T+3 for specific segments / scrips on rolling settlement; M for monthly delivery (commodities).
  4. Exchange — NSE / BSE / MCX (where the trade was matched).
  5. Segment — CM (cash market) / FNO (equity derivatives) / CD (currency derivatives) / COM (commodities) / IRD / Debt.
  6. Order Number — exchange-generated order ID; for traceability to the OMS event log.
  7. Trade Number — exchange-generated trade ID; specific to the matched trade.
  8. Trade Time — execution timestamp (HH:MM:SS).
  9. Security Description — the symbol or full instrument name.
  10. ISIN — International Securities Identification Number for the security.
  11. Buy / Sell — direction of the trade.
  12. Quantity — number of units traded (shares, lots for derivatives, kg for commodities).
  13. Trade Price — execution price.
  14. Gross Value — quantity × trade price (excluding charges and taxes).
  15. Brokerage — the broker’s charge for the trade. For T+0 trades, brokerage may differ from T+1 brokerage; the difference must be transparently disclosed (per SETTLEMENT-018).
  16. Exchange Transaction Charges — fee collected by the exchange (per-trade or basis-points based, varies by segment).
  17. Clearing Charges — for self-clearing or clearing-corp-side fees, where applicable.
  18. SEBI Turnover Fee — Rs.10 per crore of turnover (subject to revision).
  19. STT (Securities Transaction Tax) — segment-specific rates (0.025% for delivery equity buy + delivery equity sell, 0.025% for intraday equity sell, etc.).
  20. GST — 18% on (brokerage + exchange charges + SEBI fee + DP charges), as applicable.
  21. Stamp Duty — state-specific stamp duty; uniformed under the Indian Stamp Act amendments since July 2020. Rates: 0.015% on delivery equity buy; 0.003% on intraday equity sell; 0.002% on F&O buy.
  22. IPFT (Investor Protection Fund Trust) charge — small per-trade contribution to IPFT (segment-specific, typically Rs.10 per crore).
  23. Net Receivable / Payable — the final cash obligation to / from the client.
  24. Total Consideration — gross value + all charges and taxes, signed.
  25. Direct-payout-to-demat indicator — added under SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/75 to indicate that securities will be credited directly to the client’s demat from CC.
  26. MTF flag — present if the trade is in MTF context, with related disclosure on MTF interest accrual.
  27. T+0 flag — present if the trade is in T+0 segment under SEBI/HO/MRD/POD-3/P/CIR/2024/172; differential brokerage disclosed.
  28. Pledge / unpledge indicator — relevant where the trade or position interacts with the pledge framework under CDSL/OPS/DP/SETT/2025/443.
Section titled “Header and footer”
  • Broker name, SEBI registration number, exchange membership numbers, GSTIN, PAN, address — header.
  • Client name, UCC, demat BO ID, PAN, residential status, KYC compliant flag — header.
  • Compliance Officer name and contact, Investor Charter URL, SCORES URL, ODR URL — footer.
  • Disclaimer text specifying that the contract note is conclusive evidence of the trade and any dispute must be raised within prescribed period.
  • Broker DSC signature — digital signature applied to the PDF, valid under IT Act 2000.

Tax invoice differences (Annexure B only)

Section titled “Tax invoice differences (Annexure B only)”

Where the broker uses Annexure B, the tax invoice is a separate document containing:

  • GSTIN of broker and client (where client is GST-registered).
  • HSN / SAC code for the service (broking services typically SAC 997152).
  • Description of taxable supply.
  • Taxable value, CGST, SGST, IGST, total GST.
  • Place of supply.

Some brokers use Annexure B specifically because their B2B (institutional) clients need a clean tax invoice for input-credit purposes.

ECN dispatch — DLT and channels

Section titled “ECN dispatch — DLT and channels”

Email dispatch

Section titled “Email dispatch”

The ECN PDF is dispatched via email to the client’s registered email address. Per INVESTOR-SERVICING-009 in the Compliance Blueprint, email dispatch must comply with DLT / IT Act / DPDP framework:

  • Sender domain configured with DKIM / SPF / DMARC records (anti-phishing).
  • Opt-in registered for transactional communications.
  • Unsubscribe trail maintained.
  • Email server logs preserved for evidence.

The email subject line typically reads: “Contract Note for [DATE] - [Client UCC]”; the body contains a brief summary and a link or attachment to the ECN PDF.

SMS dispatch with DLT-approved template

Section titled “SMS dispatch with DLT-approved template”

In addition to email, brokers must dispatch a link to the ECN via SMS per NSE/INSP/52604 (June 10, 2022, permitting SMS / instant-messaging delivery in addition to email). The SMS channel uses DLT-approved templates with a registered Sender ID:

  • Sender ID — registered with the telecom operator’s DLT registry (TRAI Commercial Communications Customer Preference Regulations 2018).
  • Template — pre-approved by the DLT registry.
  • Header — recognized broker brand header.

A typical DLT-approved SMS template:

Dear [CLIENT NAME], your contract note for trades on [DATE]
is available at [URL]. STN: [STN_NUMBER] | -[BROKER_NAME]

The URL is typically a unique-per-client-per-day signed link to download the ECN PDF.

DLT non-compliance leads to telco blocking of the SMS, SEBI inspection observations, and SCORES complaint exposure. Phishing mitigation is reinforced by SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2024/96.

Preserved-channel log

Section titled “Preserved-channel log”

Both email and SMS dispatch produce evidence of dispatch. Brokers must preserve:

  • Email server log (SMTP logs, delivery receipts).
  • SMS gateway log (DLT submission acknowledgement, telco delivery acknowledgement).
  • ECN PDF archived for the 8-year retention period.

The preserved-channel log is the broker’s evidence that dispatch happened on schedule; SEBI inspections sample this log.

Physical dispatch (opt-in only)

Section titled “Physical dispatch (opt-in only)”

Per INVESTOR-SERVICING-014, physical dispatch is opt-in only — the default is electronic. Clients who specifically request physical receive the ECN by post / courier; the broker maintains a physical-despatch register with proof of delivery.

Daily margin statement

Section titled “Daily margin statement”

Format

Section titled “Format”

The daily margin statement is dispatched to clients per INVESTOR-SERVICING-002 and the guidelines in NSE/INSP/64315 (October 2024). Typical content:

  • Client identification (UCC, demat BO ID, PAN).
  • Date and time of the statement.
  • Available margin balance (cash + collateral) at start of day.
  • Margin obligations across segments (SPAN + ELM + exposure + delivery + MTM debits).
  • Free margin / available margin at end of day.
  • Margin shortfall (if any) and the action required.
  • Pledge details — pledged securities used as collateral.
  • Cash collateral and FDR / BG collateral.
  • Bank-balance summary (across BA1 / BA2 / BA3 — where applicable).

Channel and retention

Section titled “Channel and retention”

Email and app dispatch typically; SMS optional. Retention same 8-year standard.

Annual client acknowledgement

Section titled “Annual client acknowledgement”

Per industry practice, brokers obtain an annual signed acknowledgement from the client that the daily margin statements were received. This serves as evidence in disputes.

Quarterly statement of accounts

Section titled “Quarterly statement of accounts”

Trigger and timing

Section titled “Trigger and timing”

Issued quarterly, aligned to the running-account settlement cycle per CLIENT-FUNDS-003 and INVESTOR-SERVICING-003:

  • April-June quarter — settlement in July.
  • July-September quarter — settlement in October.
  • October-December quarter — settlement in January.
  • January-March quarter — settlement in April.

Per SEBI Dec 2023 (SEBI/HO/MIRSD/MIRSD-PoD-1/P/CIR/2023/187), settlement happens on the first Friday and/or Saturday of the designated settlement week each quarter, with subsequent operational details in SEBI/HO/MIRSD/POD-1/P/CIR/2025/94 and the 30-day non-traded refund rule under SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/04 (effective April 1, 2025).

Mandatory content

Section titled “Mandatory content”

Per the SEBI running-account framework, the quarterly statement must include:

  • Opening balance (cash + securities + collateral) at quarter start.
  • All trades during the quarter — full trade history with contract-note references.
  • All charges and taxes — brokerage, exchange fees, STT, SEBI fee, GST, stamp duty, depository charges.
  • Funds in / out — payments received, payments made, including upstreaming evidence.
  • Securities in / out — buys delivered, sells delivered, pledges, unpledges.
  • MTF interest accrual (if applicable).
  • Corporate action entries — dividends received, bonus units credited, etc.
  • MTM realisations for derivative positions closed during the quarter.
  • Running-account settlement details — the amount swept to client bank on the settlement date; retention authorisation reference (if client has authorised retention beyond actual exposure).
  • Closing balance at quarter end (cash + securities + collateral + MTF).
  • Statement of pledged / unpledged securities at quarter end.

Monthly statement option

Section titled “Monthly statement option”

Per INVESTOR-SERVICING-004, clients may opt for monthly running-account cycle instead of quarterly. The monthly statement covers a one-month window with the same content structure. Change between monthly and quarterly cycles requires the client’s consent.

30-day non-traded refund

Section titled “30-day non-traded refund”

Per CLIENT-FUNDS-014 and SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/04 (effective April 1, 2025), funds with the broker for a client who has not transacted in 30 calendar days and whose funds have been with the broker for over 30 days must be refunded on the upcoming monthly running-account settlement date irrespective of the client’s chosen cycle. The quarterly statement reflects any such 30-day refunds.

Authorisation for retention

Section titled “Authorisation for retention”

If the client has authorised retention of funds beyond actual exposure (e.g., to keep margin ready for upcoming trades), the authorisation must be in the prescribed format and renewed periodically. The quarterly statement references this authorisation.

Daily holding statement

Section titled “Daily holding statement”

Trigger

Section titled “Trigger”

For active accounts, per INVESTOR-SERVICING-005, brokers provide a daily holding statement showing the client’s current securities holdings, pledged status, and collateral allocations.

Content

Section titled “Content”
  • Security-wise quantity held.
  • Pledged-to-broker quantity (for MTF or margin pledge).
  • Free quantity (available for sale).
  • ISIN.
  • Current market value.
  • Day’s P&L.
  • Aggregate portfolio value.

API submission and dispatch

Section titled “API submission and dispatch”

Standardised by NSE/INSP/55039 (December 2022) for the API submission to exchange (replaces the prior weekly format). The same data is also dispatched to the client (email / app); the exchange-side API is the broker’s evidence of submission.

Bank balance API

Section titled “Bank balance API”

Same circular also covers daily bank-balance API submission across BA1 / BA2 / BA3, evidencing client-funds segregation.

Annual statement and Form 16A

Section titled “Annual statement and Form 16A”

Annual P&L / capital-gains statement

Section titled “Annual P&L / capital-gains statement”

Per INVESTOR-SERVICING-012, an annual P&L / capital-gains statement is dispatched at financial year close. Content:

  • Year-on-year trade summary by segment.
  • Realised capital gains / losses (short-term / long-term).
  • Unrealised gains / losses (for delivery holdings).
  • Charges and taxes paid year-to-date.
  • TDS deducted (if any) — Form 16A reference.
  • Other-income from the broker (e.g., MFOS interest on upstreaming).

Form 16A — TDS certificate

Section titled “Form 16A — TDS certificate”

Per INVESTOR-SERVICING-006, Form 16A (TDS Certificate) is dispatched annually for any TDS the broker has deducted (typically on dividends paid via the demat account, NRI client payouts, etc.). The form is generated from the TRACES portal (Income-tax Department), preserved as evidence, and dispatched via email.

Bundling

Section titled “Bundling”

Industry practice is to bundle the annual P&L / capital-gains statement, Form 16A, and the year-end consolidated ledger into a single annual dispatch.

Investor charter

Section titled “Investor charter”

Definition

Section titled “Definition”

The investor charter is a public-disclosure document — published on the broker’s website — that sets out the broker’s commitments to investors, the services offered, the grievance redressal mechanism, and the rights and responsibilities of investors. It is mandatory per SEBI investor-protection framework and reinforced at SCORES 2.0 launch.

Required content

Section titled “Required content”
  • Broker’s name, SEBI registration number, GSTIN, PAN, address.
  • Services offered — broking, depository, advisory (if any), MTF, etc.
  • Charges schedule — brokerage tariff, statutory charges, depository charges.
  • Grievance redressal — Compliance Officer name and contact, SCORES URL (https://scores.sebi.gov.in), IGRC procedure at exchange, ODR portal (Smart ODR per SEBI/HO/MIRSD/OIAE/IAD/P/CIR/2023/152 on Online Dispute Resolution).
  • Investor rights — right to trade, right to information, right to grievance redressal, right to portability.
  • Investor responsibilities — KYC compliance, password security, periodic statement review.
  • Important communications — DLT-approved channels, Sender ID, do-not-respond addresses.
  • Most Important Terms and Conditions (MITC) — separate but referenced from charter.

Update on regulatory change

Section titled “Update on regulatory change”

The investor charter must be refreshed on any regulatory change that affects its content. SCORES 2.0 launch on April 1, 2024 triggered a refresh — the new URL (scores.sebi.gov.in) replaced the older sebi.gov.in/scores. Per CDSL/IG/DP/GENRL/2024/593 and SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/0000013, brokers must update the SCORES 2.0 reference in the charter and app help.

Display

Section titled “Display”

The investor charter is typically displayed at:

  • Broker’s public website footer.
  • Broker’s app help section.
  • Broker’s account-opening kit.
  • Branches and AP locations (where physical premises exist).

Retention periods

Section titled “Retention periods”

The SEBI books-and-records framework prescribes minimum retention periods. Most investor-servicing artefacts are retained for 8 years (the SEBI Stock Broker Master Circular reference). Specific overlays:

ArtefactRetentionSource
Contract Note (ECN)8 yearsSEBI Stock Broker Master Circular
Daily Margin Statement8 yearsNSE / SEBI
Quarterly Statement of Accounts8 yearsSEBI running-account framework
Daily Holding Statement8 yearsNSE / SEBI
Annual Statement / Form 16A8 yearsIncome-tax Act + SEBI
MITC document8 yearsSEBI
Investor Charter (archive)8 years from updateSEBI
PMLA-relevant records (KYC, transaction records)10 yearsPMLA + SEBI AML Master Circular (SEBI/HO/MIRSD/SECFATF/P/CIR/2024/78)
Settlement evidence (pay-in / pay-out)8 yearsSEBI Stock Broker Master Circular
Order log (OMS)8 yearsNSE / SEBI
Pledge / unpledge records8 yearsCDSL / NSDL
Bank book (Form C / C1)8 yearsSEBI Stock Broker Master Circular

PMLA overrides SEBI when a record is relevant to AML — the 10-year PMLA retention applies. KYC records and transaction records of customers across the entire customer relationship (including post-closure) fall under the 10-year retention.

Retention medium

Section titled “Retention medium”

Records may be retained electronically subject to digital-signature integrity and audit-trail preservation. Most brokers retain in WORM (write-once-read-many) storage or in immutable cloud archives with cryptographic seal.

Sub-cases / edge cases

Section titled “Sub-cases / edge cases”

Multi-segment trading on a single day

Section titled “Multi-segment trading on a single day”

A client who trades in CM, F&O, and CD on the same day receives one consolidated contract note covering all segments, or three segment-specific contract notes with cross-references — the format under NSE/INSP/61999 allows either approach. Most brokers consolidate for clarity.

T+0 trades

Section titled “T+0 trades”

T+0 trades have differential brokerage that must be transparently disclosed in the ECN per SETTLEMENT-018 and SEBI/HO/MRD/POD-3/P/CIR/2024/172. The T+0 flag and the brokerage difference are recorded distinctly.

MTF trades

Section titled “MTF trades”

MTF trades have MTF-specific disclosures — MTF interest accrual, MTF pledge, MTF agreement reference. The ECN may include an MTF section or a separate MTF settlement annexure.

Block deals

Section titled “Block deals”

Block deals have minimum quantity / value thresholds and trade in dedicated windows. The contract note for a block deal is the same format as a regular contract note; the trade time and reference price disclosure indicate the block-deal window.

Auction trades

Section titled “Auction trades”

When a client’s trade is auctioned for short delivery (under NCL/CMPT/71045 auction mechanism), the auction price and the close-out cost are reflected in the next-day’s contract note as an adjusting entry. The client receives both the original contract note (showing the failed delivery) and the auction-adjustment entry.

Failed dispatch — bounce-back

Section titled “Failed dispatch — bounce-back”

If an email bounces back or an SMS fails delivery, the broker’s preserved-channel log records the failure. The broker must retry on the next business day; sustained failure (e.g., invalid email / mobile) triggers a client outreach to update contact details. The broker cannot consider the obligation discharged based on attempted-but-failed dispatch.

Client requests resend

Section titled “Client requests resend”

A client requesting resend of a historical contract note must be supplied with the original signed PDF (not a freshly generated copy). The original signature integrity is the audit trail; a re-signed copy is not equivalent.

Account closure — final statement

Section titled “Account closure — final statement”

On account closure (per CLIENT-FUNDS-018 — settle on account closure), a final statement is dispatched covering all transactions since the last quarterly statement plus the closure settlement.

NRI clients

Section titled “NRI clients”

NRI clients have PIS-related additional disclosures — segment restrictions, PIS account reference, NRE / NRO bank account designation. The contract note reflects these where applicable.

Joint account holders

Section titled “Joint account holders”

Where the trading account is held in joint names, contract notes are dispatched to the primary holder’s email / mobile by default; the joint holders are listed in the header. Joint-holder-specific dispatch is on opt-in.

Custodian-settled trades

Section titled “Custodian-settled trades”

Institutional clients whose trades are settled via a custodian may have a different settlement track — the contract note is sent to the institutional client per the give-up arrangement; the custodian confirms the take-up. The contract note flow and the give-up confirmation flow run in parallel.

Pre-open / closing auction trades

Section titled “Pre-open / closing auction trades”

Trades executed in the pre-open call auction (09:00–09:15) and the closing auction (15:30–15:40) are included in the day’s contract note with explicit time stamps indicating the auction-window execution.

Practical notes

Section titled “Practical notes”
  • [industry practice] Maintain a single internal “artefact matrix” listing each investor-servicing artefact, the regulatory source, the timing, the channel, the format, and the retention period. The matrix is referenced by both the back-office (which produces the artefacts) and compliance (which audits them).
  • [gotcha] Annexure A vs Annexure B choice should be made consistently — switching between them mid-year creates client confusion and audit-trail discontinuity. Most brokers commit to one annexure and remain on it; transitions happen only at the FY boundary with explicit communication.
  • [risk trade-off] Daily holding statement dispatch is operationally heavy (per-client, per-day). Some brokers ration to “active accounts” (defined as accounts with trades or holding-value changes in the last 30 days). The regulatory minimum is met; the operational efficiency improves.
  • [gotcha] DSC expiration is the single most common failure mode — a broker continues to “sign” ECNs with an expired DSC, producing technically-unsigned artefacts. Set a calendar alert at T-90, T-30, T-7 days before expiry.
  • [industry practice] ECN format compliance is tested in NSE inspections via sample. Inspectors typically request 10–20 contract notes across days / segments / clients and verify column-by-column against NSE/INSP/61999. Discrepancies surface as findings under NSE/INSP/53530.
  • [cost optimization] DLT-approved templates can be created with multiple variants (one for ECN dispatch, one for margin statement, one for quarterly statement, one for closure confirmation). Bundle them in one DLT registration to save per-template approval cost.
  • [gotcha] The 30-day non-traded refund rule under SEBI/HO/MIRSD/MIRSD-PoD/P/CIR/2025/04 (effective April 1, 2025) overrides the client’s chosen monthly / quarterly cycle. Compliance officers should ensure the back-office implements the rule even for clients on quarterly cycle.
  • [industry practice] Bundle annual statement, Form 16A, capital-gains statement, and the year-end ledger summary into a single annual dispatch with a unified cover note. Reduces client confusion and the broker’s dispatch operations cost.
  • [risk trade-off] SCORES 2.0 URL refresh (April 2024) was a small operational task but a frequent inspection finding for brokers who did not update website footers and app help. Subsequent refreshes (DPDP-related cookie notice, etc.) should be tracked in the compliance calendar with explicit owner and deadline.
  • [gotcha] Physical despatch is opt-in but, where opted, must be evidenced with proof of delivery. Most brokers under-document this and face SCORES exposure on disputed delivery.

Cross-references

Section titled “Cross-references”

Verified through

Section titled “Verified through”

2026-05-14

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Disclaimer: This documentation was generated using Claude Code, an AI-powered LLM by Anthropic, as a research and capability estimation exercise. AI models can hallucinate — information here may be inaccurate, incomplete, or outdated. Any resemblance to the products or documentation of any specific vendor or organization is purely coincidental and unintended. This project is not directly inspired by any particular product, vendor, or proprietary system, and no plagiarism is intended. All content is based on publicly available information. This is not legal, financial, or compliance advice.