POSH compliance: a complete guide for employers

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, known as POSH, requires every employer with 10 or more employees to build a safe, accountable workplace. Compliance is not optional, and gaps carry penalties, including fines and, on repeat offences, cancellation of licences. Beyond the law, a strong POSH framework signals to every employee that the company takes dignity seriously.

The four pillars of compliance

1. A written POSH policy, communicated to all employees.
2. An Internal Committee (IC) with the required composition at each location.
3. Awareness for all employees and specific training for IC members.
4. A defined complaint, inquiry and redressal process with strict timelines.

The Internal Committee

The IC must be constituted at every location that has 10 or more employees. Its composition is prescribed:

• A Presiding Officer who is a senior woman employee.
• At least two members from among employees, preferably committed to the cause or with relevant experience.
• One external member from an NGO or association, or a person familiar with issues of sexual harassment, to ensure independence.

At least half the members must be women. If a senior woman is not available at a location, the rules provide for nomination from another office or unit.

Policy, awareness and training

A POSH policy on paper is not enough. Employers are expected to run regular awareness sessions for all employees, so people know what harassment is, how to complain, and what protections exist. IC members need specific orientation to conduct inquiries fairly. Many organisations run POSH as a mandatory annual training, tracked to completion by department, and capture policy acknowledgement at onboarding.

The complaint and inquiry process

The Act sets out a clear process with timelines:

Stage	Indicative timeline
Filing a complaint	Within three months of the incident (extendable)
Conciliation (optional, at the woman's request)	Before inquiry, if she chooses
Inquiry	To be completed within 90 days
Report and action	Within a defined period after the inquiry

The process must protect confidentiality, prohibit retaliation, and allow interim relief such as a transfer or leave during the inquiry.

The annual report

Covered employers must prepare an annual report on the number of complaints received and disposed of during the year, and submit it to the district officer. Companies that file a board's report must also disclose POSH compliance there.

Common mistakes to avoid

• Not constituting an IC at every 10-plus location.
• Missing the mandatory external member.
• Treating POSH training as a one-time exercise.
• Ignoring the inquiry timelines.
• Failing to file the annual report.

Frequently asked questions

Does POSH apply to companies with fewer than 10 employees? The IC requirement applies at 10 or more; smaller workplaces are served by a Local Committee at the district level.

Can men file complaints under POSH? The Act specifically protects women; many companies adopt a gender-neutral policy internally in addition.

Is the external member mandatory? Yes, for the IC to be validly constituted.

Key takeaways

• Every employer with 10-plus employees needs an IC with an external member.
• A written policy, awareness and IC training are required.
• The inquiry must finish within 90 days, with confidentiality and no retaliation.
• File the annual report with the district officer.

NeevHR can run POSH as mandatory training with department-wise completion tracking, capture policy acknowledgements at onboarding, and keep the records an audit will ask for.