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For Employers · Ongoing Compliance

POSH Compliance Services

A POSH policy is required from your first employee, a formal Internal Committee from your tenth. We build and run the whole framework.

Ongoing retainer · Reviewed by the EPF Buddy compliance team · Last updated 29 July 2026

IC threshold

10 or more employees

IC composition

Min 4 members, ≥50% women, 1 external

Annual report

To the District Officer, every year — even with zero complaints

First-offence penalty

Up to ₹50,000 — doubled on repeat, licence risk

The POSH Act, 2013 applies to every workplace in India regardless of size. From 10 employees, an Internal Committee is mandatory — minimum four members, a senior woman employee presiding, at least half women, and one external member. The IC must file an annual report with the District Officer even in a zero-complaint year, and companies must now disclose POSH compliance in the Board's Report.

POSH is not paperwork compliance; it is capability compliance. When a complaint arrives, an incorrectly constituted or untrained IC turns a manageable situation into a legal and reputational crisis — inquiries have a 90-day statutory clock.

We build the full framework: compliant policy, IC constitution including a qualified external member, training for employees and the IC, and the annual report cycle — reviewed as your organisation changes.

Key Takeaway

POSH applies to every Indian workplace from day one; the Internal Committee becomes mandatory at 10 employees, with prescribed composition including an external member. Non-compliance costs up to ₹50,000 on first offence, doubles on repeat with licence-cancellation exposure, and must now be disclosed in the Board's Report — making it a director-level item.

Applicability

Does this apply to you?

Every workplace, from day one

The Act applies to all workplaces regardless of size — offices, factories, NGOs, hospitals. A policy, awareness and safe-workplace duties exist even below 10 employees.

IC mandatory at 10+

From 10 employees, a formally constituted Internal Committee with prescribed composition is compulsory — at every workplace/branch with 10+.

The Cost of Not Doing This

What non-compliance actually costs.

Escalating penalties

Fines up to ₹50,000 for non-compliance, doubling on repeat offences — with cancellation or non-renewal of business licences on the table for repeated failure.

The complaint-day test

An IC that exists only on paper fails exactly when it matters. Inquiries carry a 90-day statutory clock; improperly handled complaints create litigation, attrition and reputational damage no fine approaches.

Board-level disclosure

Companies must disclose POSH compliance — complaints received, disposed, pending beyond 90 days, IC status — in the Board's Report under rules expanded in 2025. That statement must be true, and auditors now check.

How We Handle It

The process.

1

Gap assessment

Policy, IC composition, training records and filings measured against the Act and the 2025 disclosure rules.

2

Framework build

Compliant policy, correctly constituted IC, qualified external member appointed.

3

Training

Employee awareness sessions and specialised IC training — the part that makes it real on complaint day.

4

Annual cycle

Annual report filed, IC refreshed on tenure, board-report disclosure supported, framework reviewed as you grow.

Documents we'll ask for

  • Current policy (if any) and HR handbook
  • Employee count and org structure
  • Existing IC details (if constituted)
  • Previous annual reports (if filed)

Exact requirements vary by state — we confirm them for yours when you contact us.

Key Terms

Words that decide outcomes.

Internal Committee (IC)
The statutory complaints committee mandatory at every workplace with 10+ employees: minimum 4 members, presided by a senior woman employee, at least 50% women, including one external member. Members serve up to 3-year terms.
External member
A mandatory IC member from outside the organisation — with an NGO or legal background familiar with sexual-harassment issues — bringing independence to inquiries. We provide qualified external members as part of the framework.
Local Committee
The district-level committee that hears complaints from workplaces with fewer than 10 employees (which are exempt from constituting their own IC) — the policy and awareness duties still apply to those employers.

Questions

Asked often.

Yes — the Act applies to every workplace regardless of size. Below 10 employees you are exempt only from constituting an Internal Committee (complaints route to the district Local Committee instead); the policy, awareness and safe-workplace obligations remain. If you are hiring toward 10, building the framework now is cheaper than retrofitting it under pressure.
Minimum four members: a senior-level woman employee as Presiding Officer, at least two employee members, and one external member with an NGO or legal background. At least half the members must be women, and member terms run up to three years.
The Act obliges employers to conduct workshops and awareness programmes at regular intervals, and IC members need capability training to run lawful inquiries. The accepted standard is induction coverage for joiners plus an annual refresher for all staff and the IC — which is the cycle we run.
Under Section 21, the IC files an annual report — complaints received, disposed of, and awareness programmes held — with the employer and the District Officer, required even in a zero-complaint year. It works on a calendar-year cycle; exact filing practice varies by district, which we confirm for yours.
Under Companies Act rules expanded in 2025: complaints received and disposed of during the year, complaints pending beyond 90 days, and confirmation of IC constitution. It has made POSH a director-level compliance item — a false statement here is its own exposure.
Yes — a qualified external member is part of the framework we set up, as the Act requires, along with their participation in inquiries and the IC training that makes the committee genuinely functional.

Talk to us.

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