A POSH Act compliance checklist covers everything the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and its Rules require: constituting an Internal Committee, adopting a policy, running training, meeting inquiry timelines, filing annual reports and, since 2025, disclosing complaint numbers in the Board's Report. This checklist for 2026 sets out each requirement with its source, so employers can tell what the Act requires and what is only advisory.
Most POSH programmes don’t fail because the employer doesn’t care. They fail on paperwork: an Internal Committee whose term expired last year, a policy nobody signed for, a complaint logged without a date. Since 2024 the cost of these gaps has gone up. The Supreme Court has ordered district-level surveys of Internal Committees, the SHe-Box portal has been rebuilt, and companies now report complaint numbers in the Board’s Report.
NOTE
How to read the sources below. Act means the POSH Act, 2013. Rules means the Rules made under it in 2013. Advisory and practice mean recommendations that are not, by themselves, statutory duties.
What POSH Act Compliance Means for Employers
POSH Act compliance has four moving parts: setting up the Internal Committee (IC), also called the Internal Complaints Committee (ICC); adopting and running a workplace sexual harassment policy; handling complaints within the Act’s timelines; and filing the reports the Act and connected company law now require. The sections below work through each one.
POSH Act Compliance Checklist: 12 Requirements Every Employer Must Meet
POSH Act Internal Committee Compliance Requirements
1. Constitute an Internal Committee by a written order. Every employer of a workplace must do this (Act, s. 4(1)). Where offices or units are in different places, each administrative unit needs its own IC. If a workplace has fewer than ten workers, or the complaint is against the employer, it goes to the district’s Local Committee instead (s. 6(1)).
2. Get the IC’s composition right. The Internal Committee needs a Presiding Officer who is a senior woman employee, at least two employee members, and one external member from an NGO or a person familiar with sexual harassment issues. At least half the members must be women (s. 4(2)). Terms cannot exceed three years (s. 4(3)), and a member who breaches confidentiality or meets the other grounds in s. 4(5) must be removed and replaced.
3. Pay the external member. The employer pays the external member’s fees and allowances (s. 4(4)). Rule 3 sets ₹200 per day for proceedings, plus travel reimbursement.
4. Display the notice and publish the IC’s details. The workplace must display the penal consequences of sexual harassment and the order constituting the IC (s. 19(b)). Rule 13(e) also requires the employer to declare the names and contact details of all IC members.
POSH Policy and Training Compliance Requirements
5. Adopt and circulate a POSH policy. Rule 13(a) requires every employer to formulate and widely disseminate an internal policy, charter or declaration. Keep signed acknowledgements.
TIP
How firmly Rule 13(a) is anchored in the Act’s own rule-making power hasn’t been tested in a reported decision — but treat it as a compliance requirement, not an optional extra.
6. Run POSH awareness training and IC orientation. The Act requires workshops and awareness programmes “at regular intervals” and orientation for IC members (s. 19(c); Rule 13). No frequency or duration is fixed. An annual programme and induction for new joiners is the common practice — but it is practice, not a statutory minimum.
7. Prepare managers for a first disclosure. This is practice, but it’s where complaints are most often mishandled: listen, don’t investigate, pass it to the IC promptly, and avoid any change to the woman’s duties or ratings that could look punitive.
POSH Act Annual Report and Board’s Report Disclosure Requirements
8. File the committee’s annual report. The IC prepares a report for each calendar year and sends it to the employer and the District Officer (s. 21; Rule 14). Separately, the employer includes the number of cases filed and disposed of in its own annual report, or informs the District Officer if it prepares none (s. 22). Use the form and date your District Officer notifies — the Act and Rules don’t fix one annual report deadline for every employer.
9. Companies: make the Board’s Report disclosure. Since 14 July 2025, Rule 8(5)(x) of the Companies (Accounts) Rules, 2014 requires the Board’s Report to state the number of sexual harassment complaints received, disposed of, and pending for more than ninety days, alongside the existing statement on constitution of the IC.
IMPORTANT
The IC’s annual report runs on the calendar year. The Board’s Report runs on the financial year. The two case counts will not automatically match — reconcile them rather than copying one figure into both filings.
SHe-Box Employer Requirements
10. Register on SHe-Box where your area requires it. Neither the Act nor the Rules mention the portal by name. The requirement comes from notices: district, city and State authorities — including in Mumbai and other cities — have issued area-wise notices requiring establishments to register their ICs on SHe-Box.
CAUTION
Scope, threshold and deadline differ by area. There is no single nationwide SHe-Box registration deadline. Get the notice that applies to your establishment from your District Officer or State Women and Child Development Department, and keep proof of registration.
POSH Act Record Keeping Requirements
11. Keep an inspection-ready compliance file. The appropriate Government can call for information and inspect records and the workplace (s. 25), and the employer must produce them on demand. Keep the IC order, display notice, policy and acknowledgements, training records, annual reports and a case register together.
12. Track the calendar, not just the paperwork. Tenure end-dates, awareness sessions, the annual report and the Board’s Report reconciliation all run on their own clocks (see the timelines below). A single compliance calendar prevents any one of them from lapsing silently.
POSH Act Compliance Timelines and the Complaint Handling Process
Once a complaint is filed, the POSH Act sets a fixed inquiry timeline:
| Step | Time limit | Source |
|---|---|---|
| Complaint by the aggrieved woman | 3 months from the incident or last incident; up to 3 more months if the committee records reasons | Act, s. 9(1) |
| Copy of complaint to respondent | 7 working days | Rule 7(2) |
| Respondent’s reply | 10 working days from receiving the documents | Rule 7(3) |
| Inquiry completed | 90 days | Act, s. 11(4) |
| Report to employer | 10 days from completing the inquiry | Act, s. 13(1) |
| Employer acts on recommendations | 60 days from receipt | Act, s. 13(4) |
| Appeal | 90 days from the recommendations | Act, s. 18(2) |
At least three IC members, including the Presiding Officer, must be present at hearings (Rule 7(7)).
WARNING
The three-month complaint window is applied strictly. In August 2026 a Division Bench of the Calcutta High Court held that it runs from the last incident, not from any later apprehension of harassment. Log the date of every complaint on the day it arrives — it decides whether the complaint is in time.
POSH Act Compliance Obligations: What’s Legally Required vs What’s Advisory in 2026
Three 2026 developments are often described as “new POSH rules.” They aren’t all the same kind of obligation.
- Supreme Court directions (binding on the authorities addressed). In continuing proceedings in Aureliano Fernandes v. State of Goa, the Court directed States and Union Territories, from December 2024, to survey whether public and private organisations have constituted ICs, with the help of Labour Commissioners, and set a six-week deadline in August 2025. Expect enquiries from District Officers and Labour Departments.
- The NCW advisory of 19 June 2026 (advisory, not law). The National Commission for Women advised States and Union Territories to set up POSH monitoring cells and to require annual POSH audits for establishments with ten or more persons. An advisory doesn’t amend the Act or the Rules. An annual audit is still a sensible control — but it’s a recommendation, not a statutory obligation.
WARNING
“The Act now covers all genders” — not supported. Some pages claim a 2026 amendment made the Act gender-neutral. We found no Gazette record of it, and the India Code text still defines the aggrieved woman as a woman (s. 2(a)). An employer can offer a gender-inclusive internal policy, but a complaint from someone who isn’t an aggrieved woman sits outside the Act’s statutory process.
POSH Compliance Audit Checklist: Common Gaps to Fix First
- An IC order whose member terms have expired, or a vacancy (no external member, for instance)
- A policy that’s not signed for, or a notice that doesn’t name the current IC members
- Complaint dates not recorded, so the three-month limit can’t be tested
- Case numbers in the IC’s annual report (calendar year) that don’t match the Board’s Report (financial year)
- No SHe-Box registration where your area’s notice requires it
Frequently Asked Questions
Is a POSH policy mandatory under the Act?
Yes. Rule 13(a) requires every employer to formulate and widely disseminate one. Its content isn't prescribed, but it should cover the complaint process, timelines and confidentiality.What are the POSH Act Internal Committee requirements?
A woman Presiding Officer at senior level, at least two employee members, one external member, and at least half the total members women (s. 4(2)), constituted by written order (s. 4(1)).What is the POSH annual report deadline?
The Act asks for the IC's report in each calendar year, in the form and at the time prescribed (s. 21) — but doesn't fix one date for every employer. Check the date your District Officer notifies.Do all companies need SHe-Box registration?
Only where a district, city or State notice requires it. Coverage is area-wise, not nationwide by the Act itself. Confirm the notice that applies to your establishment.What happens if an employer doesn't meet POSH Act obligations?
Failing to constitute an IC, act on recommendations, or meet other duties under the Act or Rules is punishable with a fine of up to ₹50,000, with higher consequences — including licence cancellation — on repeat conviction (s. 26).How long does a POSH inquiry take under the Act?
The Act sets 90 days for completing the inquiry (s. 11(4)). Courts haven't treated an overrun as automatically voiding the inquiry, but it must be reported as a case pending for more than ninety days.Need the Full POSH Act Compliance Guide for 2026?
This checklist is the outline. The Complete Manual on POSH Compliance (2026 Edition) is the full, rule-by-rule guide: 84 pages and 28 chapters, from defining the workplace to the appeal stage, with every timeline sourced to the Act or the Rules. Each section is tagged by its authority — Act, Rules, judgment, interpretation or practice — and questions the law hasn’t settled are flagged instead of glossed over. It includes 17 working annexures: a model policy, the IC constitution order, a complaint form, the notice to the respondent, an inquiry report format, the annual report, registers, hearing and evidence records, and an audit checklist.
Get The Complete Manual on POSH Compliance (2026 Edition) →
This article is general information as at September 2026 and is not legal advice. Check the current text of the Act and Rules, and any notice issued by your District Officer or State, before relying on a particular point.