Although the FA altered its rules in the summer to make it easier to take retrospective action using video evidence, it was unable to charge Torres as part of the incident had been seen by a match official.
Dyke admitted that the current position "can't be right" and needs further change.
He told the Leaders in Football conference at Stamford Bridge: "When millions of fans watching on TV can see an incident like this and the FA does not take action it is understandably baffling to everybody and has to be addressed.
"For the FA's disciplinary department to find itself in a position where it is not able to take action against an obvious scratch just can't be right.
"What this means is, despite the rules being changed in the summer, they clearly weren't changed enough.
"As FA chairman I don't like to be in a position where I cannot explain the rules when action should be taken when something is pretty obvious."
Dyke's comments will no doubt please Tottenham manager Andre Villas-Boas, who was infuriated by the FA's lack of action against Torres.
While the Spaniard was eventually sent off for two yellow cards later in the 1-1 draw, the Spurs boss branded the inability to act on the incident with Vertonghen "disgraceful" and "farcical".
"It's extremely difficult to know where to start," Villas-Boas said, speaking in Russia last week ahead of the Europa League clash with Anzhi.