POSH Act Compliance Guide for Companies (ICC Setup and Filing)

POSH compliance company obligations under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, require every employer with 10 or more employees to constitute an Internal Complaints Committee, adopt a written POSH policy, conduct annual awareness training, handle complaints within prescribed timelines, and file an annual return to the District Officer by 31 January each year. The POSH Act replaced the Supreme Court's Vishaka Guidelines of 1997 and applies to all types of organisations: Private Limited Companies, LLPs, Public Limited Companies, startups, partnership firms, and sole proprietorships.

This guide covers every aspect of POSH compliance for 2026, including ICC composition under Section 7, Local Complaints Committee provisions under Section 6, policy drafting requirements, complaint handling procedures under Sections 9 to 13, annual return filing under Section 21, penalty provisions under Section 26, and specific requirements for different entity types. First-year POSH compliance costs range from ₹15,000 to ₹50,000, and annual recurring costs range from ₹10,000 to ₹35,000 depending on organisation size and employee count.

What is the POSH Act 2013?

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 is the primary Indian legislation that protects women from sexual harassment at the workplace and establishes a mechanism for complaint redressal. The Act was enacted on 23 April 2013 and came into force on 9 December 2013 through a government notification.

The POSH Act defines sexual harassment under Section 2(n) to include 5 categories of unwelcome conduct: physical contact and advances, demand or request for sexual favours, sexually coloured remarks, showing pornography, and any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature. The definition also covers implied or explicit promise of preferential treatment in employment, threat of detrimental treatment, interference with work, and creating an intimidating, hostile, or offensive work environment.

Before the POSH Act, workplace sexual harassment was addressed through the Supreme Court's Vishaka Guidelines issued in 1997 in the landmark case of Vishaka and Others vs. State of Rajasthan. While the Vishaka Guidelines established the employer's duty to prevent sexual harassment, they operated as judicial directives without statutory penalties. The POSH Act codified these guidelines into law, introduced the ICC and LCC structure, set strict timelines for inquiry and action, and prescribed penalties for non-compliance.

The Act applies to both the organised and unorganised sectors. Every workplace as defined under Section 2(o) falls within its scope, including government departments, private companies, NGOs, hospitals, educational institutions, sports institutions, and any place visited by an employee during the course of employment. The 2013 Rules issued under the Act provide detailed procedural requirements for ICC constitution, inquiry conduct, and annual return filing.

Who Must Comply with the POSH Act?

Section 4 of the POSH Act mandates every employer with 10 or more employees at any workplace to constitute an Internal Complaints Committee. The employee count includes all categories of workers at the workplace: regular, temporary, ad hoc, daily wage, contractual, co-opted, probationary, apprentice, and interns (paid or unpaid). The threshold is assessed at the workplace level, not at the company level.

The term "workplace" under Section 2(o) is defined broadly. It includes any establishment, enterprise, institution, office, branch, or unit of the organisation. It also covers any place visited by the employee during the course of employment, including transportation provided by the employer, client offices, conference venues, and work-from-home locations. For companies with multiple offices, each office where 10 or more employees work requires a separate ICC.

Internal Complaints Committee (ICC): Composition and Setup

The ICC is the cornerstone of POSH compliance. Section 4 mandates its constitution, and Section 7 prescribes its composition. Every employer with 10 or more employees must constitute the ICC through a written order specifying the names, designations, and contact details of each member.

ICC Composition Under Section 7

At least 50% of the total ICC members must be women under Section 7(2). For example, a 4-member ICC (1 Presiding Officer + 2 employee members + 1 external member) must have at least 2 women members, which the Presiding Officer being a woman already satisfies along with 1 additional woman member.

ICC Member Tenure and Replacement

Each ICC member serves a maximum term of 3 years from the date of nomination under Section 7(3). Members can be re-nominated for one additional term. An ICC member must be removed and replaced if they are convicted for any offence, found guilty in a sexual harassment inquiry, or found guilty of an offence involving moral turpitude. The employer must fill any vacancy within a reasonable time to maintain the ICC's prescribed composition.

Who Can Be the Presiding Officer?

The Presiding Officer must be a senior woman employee at the workplace. "Senior" is not defined by a specific designation but generally means an employee at a supervisory or managerial level. If a senior woman employee is not available at the workplace, the employer may nominate a Presiding Officer from another workplace of the same employer, or from any other workplace as prescribed under Rule 4. This situation commonly arises in smaller offices or male-dominated industries.

Local Complaints Committee (LCC)

Section 6 of the POSH Act requires the District Officer (typically the District Magistrate or Additional District Magistrate) to constitute a Local Complaints Committee in every district. The LCC handles complaints from women working in establishments with fewer than 10 employees, women in the unorganised sector, and cases where the complaint is against the employer.

LCC Composition

The LCC consists of a Chairperson nominated from amongst eminent women in the field of social work (committed to the cause of women), one member nominated from women working in a block, taluka, or ward, two members (at least one must be a woman) nominated from among NGOs or associations committed to the women's cause, and the concerned officer of the Women and Child Development Department as an ex-officio member. The District Officer notifies the LCC composition in the Official Gazette.

When to Approach the LCC

An aggrieved woman should file a complaint with the LCC in 3 scenarios: (1) the workplace has fewer than 10 employees and no ICC exists, (2) the complaint is against the employer who is responsible for constituting the ICC, and (3) the employer has failed to constitute an ICC despite having 10 or more employees. The LCC follows the same inquiry procedure as the ICC under Sections 9 to 13.

LCC vs ICC Jurisdiction

The LCC's jurisdiction is limited to the district where it is constituted. If a complaint involves incidents across multiple districts, the LCC of the district where the workplace is located has primary jurisdiction. The LCC has the same powers as the ICC for conducting inquiries, recommending action, and granting interim relief. However, the LCC submits its annual report to the State Government through the District Officer, while the ICC submits to the employer and the District Officer. Employers with fewer than 10 employees should inform their employees about the LCC's existence and provide the contact details of the District Officer for complaint filing.

POSH Policy: Drafting and Implementation

A written POSH policy is the foundation document that communicates the employer's commitment to preventing sexual harassment and outlines the mechanism for complaint redressal. While the POSH Act does not prescribe a specific policy format, Section 19 mandates the employer to provide a safe working environment and display information about the complaint mechanism.

Required Policy Elements

Every POSH policy must include the following components:

• Zero-tolerance statement from the management against sexual harassment at the workplace
• Definition of sexual harassment as per Section 2(n) of the POSH Act, covering all 5 categories of unwelcome conduct
• Definition of workplace covering all locations, transport, and remote work setups per Section 2(o)
• ICC composition with names, designations, and contact details of all members
• Complaint filing procedure specifying how and where to submit a written complaint within 3 months
• Conciliation option under Section 10 and the conditions under which it can be pursued
• Inquiry procedure including timelines (90 days), rights of both parties, and principles of natural justice
• Interim relief provisions such as transfer, leave, or change in reporting structure during inquiry
• Disciplinary actions for proven misconduct: warning, censure, withholding promotion or increment, termination
• Confidentiality obligations under Section 16 and penalties for breach of confidentiality
• Protection against retaliation for the complainant, witnesses, and ICC members
• False complaint provisions under Section 14 (action only if complaint is proven malicious, not merely unsubstantiated)

Communicating the Policy to Employees

Under Section 19(c), the employer must display the POSH policy and ICC details at a conspicuous place in the workplace in English and the local language. Best practices include:

• Physical notice boards at reception, break rooms, and common areas
• Company intranet page dedicated to the POSH policy with downloadable documents
• Email communication to all employees when the policy is adopted or updated
• Inclusion in the employee handbook and offer letter annexure
• POSH policy acknowledgement form signed by every employee

Annual Policy Review and Update

The POSH policy should be reviewed and updated at least once a year. Trigger points for policy revision include changes in ICC composition (member resignation, transfer, or term expiry), amendments to the POSH Act or Rules, changes in the company structure (new offices, mergers, acquisitions), and feedback from ICC members based on their experience handling complaints or conducting inquiries. Maintain version control with a "Last Updated" date on every policy document. When the policy is updated, circulate the revised version to all employees by email and update physical notice board displays within 7 days.

POSH Policy for Remote and Hybrid Workplaces

Companies with remote or hybrid work arrangements must extend their POSH policy to cover digital workplace interactions. The policy should explicitly state that the following constitute workplace interactions under Section 2(o): video calls, conference platforms, instant messaging applications, email communications, social media interactions related to work, and any digital platform used for official purposes. Sexual harassment during online meetings, through inappropriate messages on work chat applications, or via work email carries the same consequences as in-person conduct. The ICC has jurisdiction over complaints arising from these digital interactions.

Step-by-Step POSH Compliance Process

Step 1: Verify POSH Applicability for Your Workplace

Count all employees at each workplace, including regular, temporary, contractual, part-time, and intern workers. If any workplace has 10 or more employees, the employer must constitute an ICC at that location. Multi-location companies must conduct this assessment for each branch, office, or unit separately. The employee count is assessed on an ongoing basis, not just at year-end.

Step 2: Constitute the Internal Complaints Committee (ICC)

Issue a formal written order naming the Presiding Officer (senior woman employee), at least 2 employee members committed to the cause of women, and 1 external member from an NGO or women's organisation. Ensure at least 50% of ICC members are women. File the ICC composition with the District Officer. The ICC appointment order should specify each member's designation, department, contact details, and the 3-year term of appointment.

Step 3: Draft and Adopt the POSH Policy

Prepare the POSH policy covering the definition of sexual harassment per Section 2(n), complaint filing procedure, inquiry timeline (90 days), disciplinary actions for proven misconduct, confidentiality obligations under Section 16, and the rights of both the complainant and the respondent. Get the policy approved through a Board resolution (for companies) or a management order (for other entities). Date the policy and maintain version control for future updates.

Step 4: Display the POSH Policy at the Workplace

Post notices in English and the local language at conspicuous locations: reception, common areas, break rooms, and notice boards. The notice must display the ICC member names and contact details, the complaint filing process, the penal consequences of sexual harassment under the POSH Act, and the penal consequences of making a false or malicious complaint. For remote workforces, send the policy by email and publish it on the company intranet.

Step 5: Conduct POSH Awareness Training for All Employees

Organise mandatory training covering the POSH Act provisions, the definition of sexual harassment, the complaint process, ICC composition, and employee rights. Section 19(b) requires "workshops and awareness programmes at regular intervals." Best practice is to conduct training at least once a year for all employees and separately for ICC members. New employees must receive POSH training during their induction programme within the first month of joining.

Step 6: Set Up the Complaint Receiving Mechanism

Establish a formal complaint submission process. The aggrieved woman can file a written complaint to the Presiding Officer or any ICC member within 3 months of the last incident (extendable by 3 months). Provide physical and email submission options. The ICC must acknowledge receipt of the complaint in writing. Maintain a complaint register logging the date, complainant details, respondent details, nature of complaint, and action taken.

Step 7: Establish the Inquiry and Conciliation Procedure

Document the ICC's inquiry process: send complaint copy to the respondent within 7 working days, receive the respondent's reply within 10 working days, conduct the inquiry following principles of natural justice (both parties present evidence and examine witnesses), and complete the inquiry within 90 days under Section 11. Before initiating a formal inquiry, offer the conciliation option under Section 10 if the complainant requests it. No monetary settlement is permitted during conciliation.

Step 8: Implement Action on ICC Inquiry Reports

The ICC submits its inquiry report and recommendations to the employer within 10 days of completing the inquiry. Under Section 13, the employer must act on the recommendations within 60 days. Actions include written apology, warning, withholding promotion or increment, suspension, termination, or community service. The employer must also calculate and direct deduction of compensation from the respondent's salary payable to the aggrieved woman under Section 15.

Step 9: Maintain Records and Documentation

Preserve all complaints, inquiry proceedings, ICC meeting minutes, conciliation records, inquiry reports, action taken reports, and training attendance records for a minimum of 3 years. Section 16 mandates strict confidentiality for all records. These documents form the basis for the annual return and serve as evidence of compliance during inspections. Store records securely with restricted access limited to ICC members and authorised personnel.

Step 10: File the POSH Annual Return to the District Officer

The ICC prepares the annual report containing the number of complaints received, complaints disposed of, cases pending beyond 90 days, and nature of action taken. The employer submits this to the District Officer by 31 January each year under Section 21. Include the number of awareness programmes conducted during the year. Companies must also include this information in their annual report under Section 22 of the POSH Act. Even if no complaints were filed during the year, a nil annual return confirming zero complaints and listing the training sessions conducted is mandatory. The return also covers any recommendations the ICC has made for improving workplace safety conditions, and any suggestions for policy modifications based on the year's experience.

POSH Awareness Training Requirements

Section 19(b) of the POSH Act requires the employer to organise workshops and awareness programmes at regular intervals for all employees. Training is not a one-time activity; it is an ongoing compliance requirement that must be conducted periodically. The Ministry of Women and Child Development's handbook on the POSH Act recommends annual training at a minimum.

Training Needs Assessment

Before designing the training programme, assess the organisation's specific needs. Consider the industry sector (high-interaction industries like hospitality, healthcare, and retail require more detailed training), the workforce composition (organisations with a large proportion of contract workers need customised training modules), geographic spread (multi-location companies may need regional language versions), and the history of complaints (organisations with prior incidents should address those patterns without revealing identities). A well-designed training needs assessment ensures that the programme covers relevant scenarios and resonates with the audience.

Annual Training for All Employees

Every employee must attend POSH awareness training covering:

• Definition of sexual harassment under Section 2(n) with real-world examples (without identifying actual cases)
• The company's POSH policy and zero-tolerance commitment
• ICC composition, member names, and how to file a complaint
• Rights of the aggrieved woman: confidentiality, interim relief, no retaliation
• Rights of the respondent: presumption of innocence, right to present evidence, right to a hearing
• Consequences of sexual harassment: disciplinary action, compensation, and criminal liability
• Consequences of filing a false or malicious complaint under Section 14

Training sessions can be conducted in-person, through video conferencing, or via e-learning modules. The employer must maintain attendance records signed by each participant. Annual training is typically scheduled in April or May to coincide with the start of the financial year.

ICC Member Training

ICC members require specialised training beyond the general employee awareness session. ICC training covers:

• Detailed provisions of the POSH Act and Rules, including Sections 9 to 16
• Inquiry procedures: receiving complaints, sending notice to the respondent, conducting hearings, recording evidence
• Principles of natural justice as they apply to POSH inquiries
• Drafting the inquiry report and making recommendations under Section 13
• Handling interim relief requests under Section 12: transfer, leave, or restraining order
• Conciliation procedures under Section 10 and their limitations
• Confidentiality obligations under Section 16 and penalties for breach

New Employee Orientation

Section 19(d) requires the employer to include POSH awareness in the service rules or standing orders of the establishment. New employees must receive POSH orientation during their induction programme. The orientation should cover the POSH policy, the ICC composition, the complaint filing process, and the employee's rights. A signed acknowledgement confirming receipt of the POSH policy should be collected and maintained in the employee's personnel file.

Training Documentation and Records

Maintain detailed records for every training session conducted. Each record should include the date, time, and location of the session, name and credentials of the trainer, the training agenda and content covered, an attendance register with employee signatures, and any feedback or evaluation forms collected from participants. These records serve as evidence of compliance during District Officer inspections and annual return preparation. Digital training platforms should generate completion certificates that can be exported as PDF reports for the compliance file.

Complaint Handling Process Under the POSH Act

The complaint handling process under the POSH Act follows a structured timeline from filing to final action. Understanding each stage and its deadline is critical for both the ICC and the employer.

Complaint Filing (Section 9)

The aggrieved woman files a written complaint to the ICC within 3 months of the last incident of sexual harassment. The ICC can extend this by another 3 months if satisfied that circumstances (such as health reasons or fear of retaliation) prevented timely filing. Six copies of the complaint along with supporting documents and names of witnesses must be submitted. If the woman is unable to file in writing due to physical or mental incapacity, the Presiding Officer must assist her in reducing the complaint to writing.

Complaint Timeline

Interim Relief During Inquiry (Section 12)

During the pendency of the inquiry, the ICC may recommend interim measures to the employer under Section 12:

• Transfer the aggrieved woman or the respondent to a different workplace
• Grant leave to the aggrieved woman up to 3 months (in addition to regular leave entitlement)
• Restrain the respondent from reporting on or evaluating the complainant's work
• Restrain the respondent from contacting or communicating with the complainant

The employer must implement the ICC's interim relief recommendations. The leave granted under Section 12 is paid leave and does not reduce the woman's regular leave balance.

Action on Proven Complaints (Section 13)

If the ICC concludes that the allegation of sexual harassment is proven, it recommends action to the employer under Section 13(3). The ICC may recommend any of the following actions against the respondent: written apology, formal warning, censure, withholding promotion for a specified period, withholding pay rise or increment, termination of service, undergoing counselling sessions, or performing community service. The recommendation must be proportionate to the severity of the misconduct and the circumstances of the case.

Under Section 15, the ICC also determines the compensation amount payable to the aggrieved woman by the respondent. The compensation calculation considers the mental trauma, pain, suffering, and emotional distress caused, the loss of career opportunity, the medical expenses incurred by the victim, the income and financial status of the respondent, and the feasibility of making a lump-sum or instalment payment. The employer deducts the compensation from the respondent's salary in accordance with the ICC's direction.

Action on Unproven Complaints

If the ICC finds that the allegation is not proven, it records a finding to that effect in its inquiry report. The ICC does not recommend any action against the respondent in such cases. Section 14 provides that the ICC may recommend action against the complainant only if it concludes that the complaint was malicious or knowingly false. A complaint that is merely not proven or not substantiated by sufficient evidence does not attract action against the complainant. This distinction protects women from retaliation for filing genuine complaints that may not result in a finding of guilt.

POSH Annual Return Filing

Section 21 of the POSH Act mandates the ICC to prepare an annual report and submit it to the employer and the District Officer. This report must be filed by 31 January of the calendar year following the year for which the report is prepared.

Contents of the Annual Return

The annual report under Section 21 read with Rule 14 must contain:

• Number of complaints of sexual harassment received during the calendar year
• Number of complaints disposed of during the year
• Number of cases pending for more than 90 days
• Number of workshops or awareness programmes conducted for employees
• Nature of action taken by the employer on ICC recommendations

Filing Procedure

The ICC Presiding Officer compiles the annual data, drafts the report, and submits it to the employer. The employer then files the report with the District Officer of the district where the workplace is located. There is no prescribed online portal for filing; most districts accept physical submissions or email submissions to the District Magistrate's office. Maintain a copy with the acknowledgement stamp for compliance records.

Disclosure in Company Annual Report (Section 22)

Section 22 of the POSH Act requires the employer to include information about the ICC's annual report in the company's annual report. For companies governed by the Companies Act, 2013, this means disclosing the number of complaints filed, disposed of, and pending in the Board's Report or the Directors' Report annexed to the financial statements. Listed companies must additionally disclose POSH compliance in their Business Responsibility and Sustainability Report (BRSR).

Penalties for POSH Non-Compliance

Section 26 of the POSH Act prescribes penalties for employers who fail to comply with the Act's provisions. The penalty structure targets both first-time and repeat non-compliance.

The licensing authority that granted the business licence or registration has the power to cancel or withdraw it for repeat offences. For companies registered under the Companies Act, 2013, this means the ROC can be directed to take action. For shops and establishments, the licence under the Shops and Establishments Act can be revoked. The severity of this consequence makes POSH compliance a business continuity issue, not just an HR formality.

Impact on Business Operations Beyond Penalties

The financial penalty under Section 26 represents only the statutory minimum consequence. In practice, POSH non-compliance creates several additional business risks. Investors and venture capital firms conduct POSH compliance checks during due diligence before funding rounds. Companies applying for government tenders or public procurement contracts may face disqualification if POSH compliance records are incomplete. ESG rating agencies score POSH compliance under the governance pillar, and a low ESG score can restrict access to sustainability-linked financing. Listed companies face scrutiny from SEBI through the Business Responsibility and Sustainability Report disclosures. Recruitment platforms and employer branding surveys increasingly assess POSH compliance as an indicator of workplace culture, affecting the company's ability to attract talent.

Criminal Liability Under the Indian Penal Code

The POSH Act penalty exists alongside criminal liability. The complainant can file a First Information Report (FIR) under Section 354A of the Indian Penal Code, 1860 (now Section 74 of the Bharatiya Nyaya Sanhita, 2023) for sexual harassment, which carries imprisonment of up to 3 years and a fine. Section 354B (assault or use of criminal force with intent to disrobe), Section 354C (voyeurism), and Section 354D (stalking) may also apply depending on the nature of the incident. The criminal proceedings run independently of the ICC inquiry, and the employer's failure to provide a safe working environment under Section 19 can be cited as contributory negligence during criminal or civil proceedings.

POSH Compliance for Different Entity Types

While the POSH Act applies uniformly to all employers with 10+ employees, reporting and disclosure obligations vary by entity type.

Common Mistakes in POSH Compliance

After advising over 300 companies on POSH compliance, these are the errors we encounter most frequently:

1. Not Including an External Member in the ICC

Section 7(1)(c) mandates at least 1 external member from an NGO or association committed to women's cause. Many companies constitute the ICC entirely from internal employees, which violates the Act. The external member brings independent oversight and credibility to the inquiry process. Contact the District Women and Child Development office for a list of eligible NGOs.

2. Treating POSH Compliance as a One-Time Activity

Constituting the ICC and drafting the policy is the starting point, not the end. POSH compliance requires annual training, regular ICC meetings, ongoing display of policy notices, timely complaint handling, and annual return filing by 31 January every year. Companies that do not maintain ongoing compliance face penalties during District Officer inspections.

3. Not Counting Contractual and Temporary Workers

The 10-employee threshold under Section 4 includes all categories of workers: regular, temporary, ad hoc, contractual, apprentice, and interns. Companies that count only permanent employees may incorrectly conclude they are below the threshold. A company with 6 permanent employees and 5 contractual workers has 11 employees and must constitute an ICC.

4. Failing to Conduct Annual Awareness Training

Section 19(b) requires workshops "at regular intervals." Many companies conduct one training session during ICC formation and never repeat it. The Ministry of Women and Child Development expects annual training. District Officers check training attendance records during inspections. Maintain signed attendance registers and training completion certificates for every session.

5. Not Filing the Annual Return by 31 January

Even if no complaints were received during the year, the ICC must file the annual return to the District Officer by 31 January under Section 21. A "nil" return confirming zero complaints and listing the training sessions conducted is still required. Non-filing is a compliance gap that can attract action under Section 26 during a surprise inspection or audit.

6. Inadequate Confidentiality Safeguards

Section 16 prohibits publishing or making known the contents of a complaint, inquiry proceedings, or the identity of the complainant, respondent, or witnesses. Companies that discuss ongoing complaints in team meetings, share details with managers outside the ICC, or fail to restrict access to complaint records violate this provision. A fine of up to ₹5,000 per breach applies, and the employer faces reputational risk.

7. Not Reconstituting the ICC After Term Expiry

Each ICC member serves a 3-year term under Section 7(3). Many companies forget to track ICC term expiry dates and continue operating with members whose terms have lapsed. An ICC with expired-term members is effectively an improperly constituted committee, and its inquiry reports can be challenged in court. Set calendar reminders for ICC reconstitution 2 months before the 3-year term ends. Issue a fresh appointment order for continuing members and replace members who have left the organisation.

8. No Written Complaint Mechanism for Remote Workers

Companies with remote or hybrid employees often lack a digital complaint submission channel. The POSH Act requires a written complaint, but Section 9 allows the Presiding Officer to assist if the complainant cannot file in writing. For remote workers, provide a dedicated email address, a secure online form, or a confidential portal for filing complaints. Ensure the complaint reaches the ICC Presiding Officer directly without passing through HR managers or reporting supervisors, which could compromise confidentiality and deter reporting.

POSH Compliance Cost Breakdown

POSH compliance costs cover policy drafting, ICC setup, training, external member fees, and annual return filing. The table below outlines typical costs for small and mid-size companies.

Companies with more than 100 employees or multiple locations incur higher costs due to separate ICC setups at each location, larger training batches, and more complex record-keeping. Companies engaging external POSH consultants for end-to-end compliance management pay ₹50,000 to ₹2,00,000 annually depending on company size. For startups and small companies with 10 to 50 employees, the most cost-effective approach is to combine POSH compliance with broader annual compliance services from a single provider. This bundled approach reduces professional fees by 20% to 30% compared to engaging separate vendors for POSH policy, training, and return filing. Companies in high-risk industries such as hospitality, healthcare, entertainment, and retail should budget for more frequent training sessions (semi-annual instead of annual) and a dedicated POSH helpline or email channel for real-time complaint reporting.

POSH Compliance Calendar for 2026

The following calendar maps every POSH compliance milestone for the calendar year 2026.

Related Resources

• Compliance Services -- End-to-end annual compliance management including POSH setup and annual return filing
• Private Limited Company Compliance -- Annual return, Board's Report, and statutory disclosures including POSH for Pvt Ltd companies
• Secretarial Compliance Services -- Board resolution drafting, policy adoption, and secretarial audit including POSH compliance verification
• Compliance Health Check -- Review pending POSH obligations, ICC tenure, training records, and annual return status
• LLP Compliance -- Annual compliance package for LLPs including POSH return filing assistance
• OPC Compliance -- Compliance management for One Person Companies including POSH obligations
• Startup Legal Services -- Legal support for startups covering POSH compliance, employment agreements, and policy drafting
• Private Limited Company Registration -- Register a new company with compliance-ready setup including POSH framework

Summary

POSH compliance for companies requires every employer with 10 or more employees to constitute an Internal Complaints Committee under Section 4 of the POSH Act 2013, draft and display a POSH policy, conduct annual awareness training under Section 19, handle complaints within the 3-month filing window and 90-day inquiry timeline, act on ICC recommendations within 60 days, and file the annual return to the District Officer by 31 January under Section 21. The ICC must consist of a Presiding Officer (senior woman employee), at least 2 employee members, and 1 external member from an NGO, with at least 50% women members and a 3-year term for each member.

Non-compliance attracts a penalty of up to ₹50,000 for the first offence under Section 26, with repeat offences risking licence cancellation. First-year POSH compliance costs range from ₹15,000 to ₹50,000, and annual recurring costs from ₹10,000 to ₹35,000. The POSH Act applies equally to Private Limited Companies, LLPs, Public Limited Companies, OPCs, startups, and partnership firms. Companies must disclose ICC compliance data in their annual report under Section 22 and maintain all records confidentially under Section 16 for a minimum of 3 years. Workplaces with fewer than 10 employees must direct complaints to the Local Complaints Committee constituted by the District Officer under Section 6.