Part of our guide to transmission of shares after death
A transmission request that comes back from the registrar feels like a rejection. Usually it isn't. It's a memo listing what's missing, and most of the items on it are quick to fix once you know what they mean.
The objections we see most
- Signature doesn't match: the claimant's signature differs from what the registrar holds, or there's nothing on record to compare. The fix is Form ISR-2, in which your bank confirms your signature.
- Name variations: the deceased's name on the death certificate differs from the folio, say initials against a full name. Send an affidavit explaining the variation, with a supporting document such as a passport or an old certificate showing both forms.
- Death certificate copy not accepted: ask the registrar what attestation it wants, and send that
- KYC incomplete on the folio: file Form ISR-1 with PAN, address and bank details
- An heir's NOC missing, or not notarised: every other legal heir's affidavit-cum-NOC is required, notarised
- Value above the simplified limit: the registrar wants a will, legal heirship certificate or succession certificate as well. Which one.
- Client Master List out of date or mismatched: it must be under two months old, attested by your depository participant, and in the claimant's exact name
Read the memo line by line and answer every point in one reply. Fixing one item at a time can cost a month per round.
Timelines the registrar works to
Since 2 April 2026, transmitted physical shares are credited directly to the claimant's demat account within 30 days of a complete request. The clock starts from when the file is complete, not from when you first posted it.
Keep a record
- Dates you sent documents, with tracking numbers
- The registrar's inward or service request number
- Copies of every memo and reply
When you escalate, this is what gets a complaint taken seriously.
How to escalate
- 1. The registrar: use its service request or grievance channel and quote your reference. KFintech and MUFG Intime both run online portals; see our guides to KFintech and MUFG Intime.
- 2. The company: write to its compliance officer or investor grievance email, listed on its investor page and in its annual report
- 3. SEBI SCORES: file a complaint on the SCORES portal at scores.sebi.gov.in. You're expected to have approached the company or registrar first. The company has 21 calendar days to resolve it, and if you aren't satisfied, the complaint can go to review and escalation.
- 4. Online dispute resolution: if the grievance is still unresolved, SEBI's Smart ODR platform offers conciliation and then arbitration for securities market disputes
When escalation won't help
If the objection is that another heir disputes the claim, no amount of escalation will get the registrar to act. Disputes are excluded from the simplified framework, and that's a matter for the courts. See when legal documents become the bottleneck.
Procedures detailed in this guide cite sovereign circulars, statutory rules, and court precedents governing Indian securities and estate transmission:
- SEBI Transmission Framework Circular (July 2026) Reference: HO/38/13/11(14)2026-MIRSD-POD/I/17111/2026SEBI
- Indian Succession Act, 1925 (Sections 370-390: Succession Certificates) Reference: Act No. 39 of 1925High Court / Supreme Court
- Supreme Court Ruling on Nominee Rights: Shakti Yezdani v. Jayanand Jayant Salgaonkar Reference: Civil Appeal No. 7107 of 2017High Court / Supreme Court
About Adv. Neha Aggarwal
Head of Legal & Compliance · B.A. LL.B, Advocate (High Court of Delhi)Practicing advocate specializing in corporate succession, probate jurisprudence, and estate asset transmission. She leads the firm’s regulatory audit panel, vetting all filings against prevailing SEBI circulars and MCA notifications.
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