Grievance Redressal Module (GRM) for Frozen Accounts: Steps, Timelines and Escalation

Before 2026, an account holder whose money was frozen in a cyber case often had no clear process other than chasing a police station in another state or filing a writ petition. The Grievance Redressal Module (GRM), set up under the MHA SOP dated 02.01.2026 and functional from April 2026 (per PIB), is the official channel for these grievances.

Quick answer: You don't log in to the GRM yourself. You submit a grievance at your bank branch. The bank re-verifies your KYC and uploads it to the GRM within 7 calendar days. The investigating officer must decide within 15 days. If not, the grievance escalates to the District Grievance Officer (15 days) and, for seizure or digital-banking suspension, to the State Grievance Officer. A conditional 90-day review applies to holds without lawful direction.

Who Can Use the GRM

1. Account holders whose money is under lien, hold, debit freeze, digital banking suspension or seizure linked to an NCRP/CFCFRMS complaint.
2. Individuals, proprietors, firms and companies alike.

GRM Timelines at a Glance (SOP para 10)

Step-by-Step: Using the GRM Through Your Bank

Step 1: Visit your home branch

Ask to file a grievance about the cyber-related hold. Request the complaint numbers and police details.

Step 2: Submit a written grievance

Explain why the credit was genuine. Attach invoices, chats, delivery proof and KYC.

Step 3: Get an acknowledgement

Ask the bank for written confirmation of the date it received your grievance. The 7-day clock runs from here.

Step 4: Track the decision

You should receive the IO's decision or reasons by SMS/email. Keep checking with the branch.

Step 5: Escalate or appeal

If the IO doesn't act, it moves to the District Grievance Officer. If you disagree with a decision, file a review within 15 days.

The 90-Day Review Explained

If no lawful direction is received within 90 days of the bank submitting a contested grievance, the bank requests the police to remove the hold and can release it after enhanced due diligence — only if the amount isn't needed in another case, no court petition is pending, and the IO hasn't sought an extension (up to 90 more days).

This is not an automatic unfreeze. Also note: Annexure-I of the SOP counts the 90 days from the date of the hold, not the grievance date. Ask your bank which date it uses.

How Well Is the GRM Working?

Data is limited and conflicting, so present it with care:

1. An I4C letter dated 03.07.2026 to the Delhi High Court showed high pendency in several states (for example, Maharashtra about 77%, Karnataka and Delhi about 92% pending) and listed 857 writ petitions on account freezes pending against I4C.
2. A later I4C/MHA status report filed in the Supreme Court on 7 October 2026 (as reported in the media) said the GRM covered 109 banks and 1.28 lakh branches by 30 September 2026, with 93,041 grievances received and 60,638 acted on.

The Supreme Court took the SOP on record on 09.02.2026, and I4C has asked people to use the GRM before approaching a High Court.

Tips for a Stronger Grievance

• Write clearly: who paid you, when, how much and for what.
• Attach documents that a third party can verify (GST invoice, courier tracking).
• Request that the hold be limited to the reported amount if more is blocked (SOP para 6.1(j)).
• Keep copies and dates of every submission.

Common Mistakes

Waiting for the police to contact you. Start the grievance at the bank yourself.

Missing the 15-day review window. Calendar it from the date you receive a decision.

Paying "GRM agents". The process is free through your bank.

Contextual Internal Links

1. Pillar: Cyber complaint against you? Check, respond and unfreeze
2. Bank account frozen — how to unfreeze
3. Letter formats

Related cyber guides:

1. Lien marked by cyber crime
2. Cybercrime tracker: check complaint status

Official External References

1. National Cyber Crime Reporting Portal
2. PIB — cyber crime mitigation update (28 July 2026)

Frequently Asked Questions

1. What is the GRM in cyber crime cases? The Grievance Redressal Module, set up under the 2026 MHA SOP, for account holders affected by cyber-complaint holds and freezes.

2. Can I apply on the GRM directly? No. You file at your bank branch, and the bank uploads the grievance to the GRM.

3. How long does the bank have to upload my grievance? Not beyond 7 calendar days, under the SOP.

4. What if the police don't respond? The grievance escalates to the District Grievance Officer, who decides within 15 days.

5. Is the 90-day review automatic? No. It requires bank due diligence and depends on conditions such as no extension sought by the IO.

Conclusion

The GRM gives account holders a defined path with deadlines. Start early at your branch, document everything, and escalate on time. If the system stalls, a court remains available.

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