What to Do When a Rating Agency Flags You as "Issuer Not Cooperating"

FinMen Advisors | Credit Rating Advisory — Problem-Specific Guide

Seeing your company's rating listed with an "Issuer Not Cooperating" tag is unsettling, and businesses that encounter it for the first time often aren't sure what it actually means or what to do next. This guide walks through what the flag represents, why it happens, and the practical steps to resolve it.

What "Issuer Not Cooperating" Actually Means

Rating agencies are required to conduct periodic surveillance on every rating they've assigned, which depends on the rated company providing updated financial statements, operational information, and responding to the agency's queries. When a company doesn't respond to repeated requests for this information, the agency is unable to complete its scheduled review — and rather than continuing to carry a rating it cannot substantiate with current information, the agency flags the rating as based on "Issuer Not Cooperating" status. It's a disclosure about the agency's ability to review the company, not a statement that the company's credit quality has necessarily worsened.

Why This Happens More Often Than You'd Expect

•        A change in the company's finance team or a point-of-contact departure, with the surveillance request landing with no one following up

•        Genuine oversight — surveillance requests treated as low priority amid other business demands

•        A company that no longer actively uses the rated facility and has deprioritised the relationship with the rating agency

•        Confusion internally about who is responsible for responding to the agency's requests

What Happens If the Flag Isn't Resolved

If a company remains non-cooperative for an extended period, agencies typically move the rating further along a defined process — which can eventually include rating withdrawal or a ratings action based on the best available public information rather than updated company data. In the meantime, an INC-flagged rating can raise questions with lenders, counterparties, or in tender processes that reference credit ratings, even before any formal rating change occurs.

Steps to Resolve an INC Flag

•        Identify exactly what information the rating agency has requested and hasn't received — this is usually stated in the agency's own published rating rationale or surveillance communication

•        Designate a single, clear point of contact internally responsible for responding to the agency going forward

•        Compile and submit the outstanding financial statements and operational updates as completely as possible, even if later than originally requested

•        Proactively communicate with the agency about the delay and confirm a realistic timeline for full compliance

•        If documentation gaps exist beyond just being late — inconsistent financials, unresolved queries from a prior cycle — address those directly rather than resubmitting incomplete information again

Preventing This Going Forward

•        Build the annual surveillance response into your finance team's regular calendar, not treated as an ad hoc request

•        Maintain a single internal owner for the rating agency relationship, with a clear handover process if that person's role changes

•        Consider ongoing advisory support for surveillance-cycle management if internal bandwidth is a recurring constraint

Frequently Asked Questions

Does an INC flag mean my company's rating has been downgraded?

Not necessarily — INC status reflects the agency's inability to complete its review with current information, which is a separate issue from the rating level itself, though prolonged non-cooperation can eventually lead to a ratings action.

How quickly can an INC flag be resolved once we re-engage?

This depends on how completely and quickly the outstanding information can be submitted, and the agency's own review timeline once it receives what it needs. Prompt, complete submission generally leads to faster resolution.

Can an advisor help resolve an existing INC flag, or only prevent future ones?

Both — advisors can help compile and submit outstanding documentation to resolve a current flag, and can also help set up processes to prevent recurrence in future surveillance cycles.

Talk to FinMen Advisors

If your company's rating has been flagged as Issuer Not Cooperating, FinMen Advisors' team can help you understand what's needed to resolve it and re-engage with the agency.

FinMen Advisors Pvt. Ltd. — India's Largest Credit Rating Advisors & Leading IPO Advisors. 15+ years | 13 branches | 80+ professionals | 6,500+ client assignments across 31+ industries.

Write to marketing@finmen.in or call +91-7738714680 to book an Initial Assessment.

Note: Credit ratings are assigned solely by SEBI-registered Credit Rating Agencies (CRISIL, ICRA, CARE, India Ratings, etc.). FinMen Advisors provides preparatory and advisory support and does not issue, influence, or guarantee rating outcomes.