POSH Compliance Checklist for Employers in India (2026)

POSH Compliance Checklist for Employers in India (2026): IC Formation, Training & Annual Reporting Sexual harassment at the workplace is not just an employee relations issue. It is a matter of workplace safety, legal compliance and organisational responsibility. In India, the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, commonly known as the POSH Act, requires employers to take specific steps to prevent sexual harassment and provide a proper complaint redressal mechanism. However, many organisations are unsure whether they have constituted their Internal Committee correctly, completed employee awareness programmes, displayed the required notices or fulfilled annual reporting obligations. Missing these responsibilities can expose an organisation to legal and reputational risks. This POSH compliance checklist for employers in India explains the key requirements businesses should review in 2026, including Internal Committee formation, employee training, complaint handling, documentation and annual reporting.

What Is the POSH Act in India?

The POSH Act, 2013, was introduced to protect women from sexual harassment at the workplace and establish a mechanism for preventing and addressing complaints. The Act places responsibilities on employers to:

• Provide a safe working environment.
• Constitute an Internal Committee where applicable.
• Display information about the POSH policy and complaint mechanism.
• Conduct employee awareness programmes.
• Organise training for Internal Committee members.
• Support fair and timely complaint inquiries.
• Maintain confidentiality.
• Fulfil applicable annual reporting requirements.

The Act applies to workplaces across the public and private sectors, subject to its definitions and provisions.

1. Constitute an Internal Committee (IC)

One of the most important POSH compliance requirements is the constitution of an Internal Committee (IC). Under Section 4 of the POSH Act, every workplace employing 10 or more employees must constitute an Internal Committee through a written order. If an organisation operates from multiple offices or administrative units, the committee must be constituted at the applicable offices or units as required by the Act.

Internal Committee composition

The Internal Committee must include:

Position	Requirement
Presiding Officer	A senior-level woman employee
Employee Members	At least two employees
External Member	One person from an eligible NGO, association or a person familiar with issues relating to sexual harassment
Women Representation	At least half of the total members must be women

The Presiding Officer and members can hold office for a period specified by the employer, not exceeding three years from the date of nomination.

Employer checklist

• Issue a formal written order constituting the Internal Committee.
• Appoint an eligible woman employee as Presiding Officer.
• Nominate at least two employee members.
• Appoint an eligible external member.
• Ensure at least 50% of committee members are women.
• Check the committee’s tenure and update appointments when required.
• Constitute committees for applicable offices and administrative units.

Important: Organisations with fewer than 10 employees, and cases involving a complaint against the employer, fall under the Local Committee mechanism established under the Act.

2. Prepare and Display the POSH Policy

Every organisation should have a clearly documented POSH policy explaining its approach to preventing and addressing sexual harassment. A written policy helps employees understand unacceptable conduct, reporting channels and the organisation’s complaint-handling process.

What should the POSH policy include?

• Definition and examples of sexual harassment.
• Scope and applicability of the policy.
• Details of the Internal Committee.
• Complaint submission procedure.
• Inquiry and redressal process.
• Confidentiality requirements.
• Protection against retaliation.
• Disciplinary action for established misconduct.
• Roles and responsibilities of employees and management.

Employers must also display information about the consequences of sexual harassment and the order constituting the Internal Committee at a conspicuous place in the workplace.

Employer checklist

• Prepare and approve a written POSH policy.
• Communicate the policy to all employees.
• Display the required information at the workplace.
• Share the complaint submission process.
• Provide accessible contact details for the Internal Committee.
• Review the policy periodically.

3. Conduct POSH Awareness Training for Employees

A POSH policy is effective only when employees understand it. Employers should organise regular awareness programmes to explain workplace conduct, employee rights and the process for reporting incidents. Training should cover employees at different levels, including new joiners, managers, supervisors and senior leadership.

Topics to cover during POSH awareness sessions

1. Meaning and examples of workplace sexual harassment.
2. Appropriate and inappropriate workplace behaviour.
3. Employee rights and responsibilities.
4. How to report a complaint.
5. Role of the Internal Committee.
6. Confidentiality and protection against retaliation.
7. Consequences of established misconduct.

Employer checklist

• Conduct POSH awareness sessions for employees.
• Include POSH information in employee induction.
• Maintain attendance records.
• Keep copies of training materials.
• Record training dates and session details.
• Conduct refresher sessions when required.

4. Train Internal Committee Members

Internal Committee members play a critical role in handling complaints fairly and following the prescribed inquiry procedure. They should understand the POSH Act, applicable rules, principles of natural justice, confidentiality and documentation requirements.

Key training areas

• Understanding the POSH Act and Rules.
• Receiving and recording complaints.
• Conducting fair and impartial inquiries.
• Maintaining confidentiality.
• Evaluating evidence and statements.
• Preparing inquiry reports.
• Recommending appropriate action.
• Understanding statutory timelines.

Employer checklist

• Provide appropriate training to IC members.
• Explain inquiry procedures and responsibilities.
• Maintain training and participation records.
• Arrange refresher training when needed.
• Review whether committee members understand their roles.

5. Establish a Proper Complaint Handling Process

Employers must ensure that employees know how to submit complaints and that the Internal Committee can handle them according to the Act. A complaint of sexual harassment should generally be made in writing within three months of the incident or, in the case of a series of incidents, within three months of the last incident. The Internal Committee may extend this period by a further period of up to three months where the statutory conditions are met and reasons are recorded.

Important complaint inquiry timelines

Activity	Timeline under the Act
Submission of complaint	Generally within 3 months of the incident or last incident
Extension for filing complaint	Up to a further 3 months, subject to statutory conditions
Completion of inquiry	Within 90 days
Submission of inquiry report	Within 10 days of completion of inquiry
Employer action on recommendations	Within 60 days of receiving the recommendations

The Act also provides for conciliation before an inquiry, at the request of the aggrieved woman, subject to its conditions. Monetary settlement cannot be made the basis of conciliation.

Employer checklist

• Provide a clear complaint submission channel.
• Ensure the Internal Committee is accessible.
• Record complaints securely.
• Follow the prescribed inquiry procedure.
• Maintain relevant records and documentation.
• Observe statutory timelines.
• Implement recommendations within the applicable period.
• Protect the confidentiality of everyone involved.

6. Maintain Confidentiality During POSH Proceedings

Confidentiality is an essential part of POSH compliance. Section 16 of the Act restricts the publication or communication of information relating to complaints, the identities of the parties and witnesses, conciliation and inquiry proceedings, recommendations and action taken. Employers should ensure that complaint-related information is shared only with authorised persons for legitimate purposes.

Employer checklist

• Restrict access to complaint records.
• Store inquiry documents securely.
• Avoid sharing identities or case details unnecessarily.
• Brief IC members and relevant employees on confidentiality.
• Avoid discussing ongoing cases in public or informal channels.
• Maintain appropriate records of actions taken.

7. Submit the POSH Annual Report

Annual reporting is another important part of POSH compliance. Under Section 21, the Internal Committee must prepare an annual report and submit it to the employer and the District Officer. The report includes prescribed information such as:

• Number of complaints received during the year.
• Number of complaints disposed of.
• Number of cases pending for more than 90 days.
• Number of awareness programmes or workshops conducted.
• Nature of action taken by the employer or District Officer.

Under Section 22, the employer must include information on the number of cases filed and their disposal in its annual report or, where such a report is not required, inform the District Officer. Employers should verify the applicable reporting process and any additional directions issued by the relevant authority.

Employer checklist

• Collect the required information from the Internal Committee.
• Prepare the annual report.
• Submit it to the employer and District Officer as required.
• Maintain a copy of the submitted report.
• Include the required POSH information in the organisation’s annual report, where applicable.
• Track pending cases and reporting obligations.

8. Register and Update Workplace Details on the SHe-Box Portal

The Ministry of Women and Child Development operates the Sexual Harassment Electronic Box (SHe-Box) portal. It provides a centralised online platform to help women access information about Internal Committees and Local Committees and submit complaints. Employers should review the portal and follow applicable government directions regarding workplace and committee details. Official portal: https://shebox.wcd.gov.in/

Employer checklist

• Review the SHe-Box portal.
• Check applicable registration and onboarding requirements.
• Verify Internal Committee information.
• Update relevant workplace and committee details where required.
• Ensure the organisation’s complaint mechanism is correctly communicated.

Complete POSH Compliance Checklist for Employers in India (2026)

Use the following checklist to review your organisation’s POSH compliance status.

Compliance Area	Action Required
Internal Committee	Constitute an IC where the Act requires it
Committee Composition	Verify all member positions and gender representation
Written Order	Issue and maintain the IC constitution order
POSH Policy	Prepare and communicate the policy
Workplace Display	Display required notices and IC details
Employee Awareness	Conduct awareness programmes
IC Training	Train committee members
Complaint Mechanism	Establish accessible reporting channels
Inquiry Procedure	Follow statutory procedures and timelines
Confidentiality	Protect complaint-related information
Annual Reporting	Prepare and submit applicable reports
SHe-Box	Review portal requirements and committee information
Documentation	Maintain policies, orders, training and reporting records

Organisations should review this checklist periodically and maintain supporting evidence for each applicable requirement.

What Are the Penalties for Non-Compliance with the POSH Act?

Employers should take POSH compliance seriously because the Act provides penalties for non-compliance. Under Section 26, an employer who fails to:

• Constitute an Internal Committee as required under Section 4.
• Take action under Sections 13, 14 and 22.
• Contravene or attempt to contravene other provisions of the Act or its Rules.

may be liable to a fine of up to ₹50,000 for the first offence. A repeat conviction can attract enhanced consequences, including a penalty that may be twice the earlier punishment and possible consequences for licences, registrations or approvals, as provided under the Act. The actual consequences depend on the nature of the violation and applicable legal provisions.

How SNGSPL Can Help with POSH Compliance

Managing POSH compliance requires more than preparing a policy document. Employers need to ensure that the Internal Committee is properly constituted, employees understand the reporting process, training is conducted and records are maintained. SNGSPL supports organisations with compliance-related services and guidance to help them strengthen their workplace compliance processes. Our POSH-related support can help businesses review areas such as:

• POSH policy documentation.
• Internal Committee constitution support.
• Employee awareness and training coordination.
• Internal Committee training support.
• Compliance documentation and record review.
• Annual reporting readiness.

If your organisation needs assistance reviewing its POSH compliance requirements, connect with our team. Explore our POSH Consultant Services or contact SNGSPL to discuss your requirements.

Frequently Asked Questions (FAQs)

1. Is POSH compliance mandatory for all companies in India?

The POSH Act applies to workplaces covered by its provisions. Every workplace employing 10 or more employees must constitute an Internal Committee. Workplaces with fewer than 10 employees and complaints against the employer are handled through the Local Committee mechanism.

2. When is an Internal Committee required?

An Internal Committee is required at a workplace employing 10 or more employees. Applicable offices and administrative units must also be considered when constituting committees.

3. Who can be appointed as the Presiding Officer?

The Presiding Officer must be a senior-level woman employee at the workplace. The Act provides alternatives where a suitable senior-level woman employee is unavailable.

4. Is an external member compulsory in the Internal Committee?

Yes. The Internal Committee must include one external member from an eligible NGO or association committed to the cause of women, or a person familiar with issues relating to sexual harassment, as specified under the Act.

5. Is POSH training mandatory for employees?

The Act requires employers to organise workshops and awareness programmes to sensitise employees. Employers should also ensure that Internal Committee members receive appropriate orientation and training to perform their duties.

6. What is the time limit for completing a POSH inquiry?

The Internal Committee must complete its inquiry within 90 days. The inquiry report must be provided within 10 days of completion.

7. Is POSH annual reporting mandatory?

The Internal Committee must prepare an annual report and submit it to the employer and District Officer. Employers also have reporting responsibilities under Section 22 of the Act.

8. What is the penalty for not constituting an Internal Committee?

Under Section 26, failure to constitute an Internal Committee as required may attract a fine of up to ₹50,000 for the first offence. Repeat offences may attract enhanced consequences.

9. What is the SHe-Box portal?

SHe-Box is an online platform operated by the Ministry of Women and Child Development. It provides information about Internal Committees and Local Committees and facilitates online submission and tracking of workplace sexual harassment complaints.

10. Can a company outsource POSH compliance?

Organisations can seek external professional support for policy reviews, training, documentation and compliance guidance. However, outsourcing support does not remove the employer’s statutory responsibilities or replace the Internal Committee required under the Act.

Conclusion

POSH compliance is an essential responsibility for employers in India. From constituting the Internal Committee to conducting awareness programmes, maintaining confidentiality and completing annual reporting, every requirement plays an important role in creating a safe and respectful workplace. Employers should not wait for a complaint or inspection to review their compliance status. A structured POSH compliance checklist can help identify gaps, improve documentation and strengthen internal processes. Need professional support with POSH compliance? Connect with SNGSPL for assistance with POSH-related compliance requirements. Visit: https://sngspl.com/services/posh-consultant-services/ Disclaimer: This article is intended for general informational purposes and does not constitute legal advice. Employers should refer to the POSH Act, applicable Rules, state-specific directions and advice from qualified legal professionals for their specific circumstances.