--- title: "POSH Compliance Calendar in India: Annual Reports, Internal Committee Reviews and Employer Filings" date: 2026-10-24 author: "Rohitaashv Sinha" url: https://ksandk.com/labour-employment/posh-compliance-calendar-in-india/ --- # POSH Compliance Calendar in India: Annual Reports, Internal Committee Reviews and Employer Filings Posted On - 24 October, 2026 • By - Rohitaashv Sinha ![](https://ksandk.com/wp-content/uploads/POSH-Compliance-Calendar-India-1.png) ## Introduction: Why POSH Compliance Requires Year-Round Monitoring Compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“POSH Act”) is an ongoing responsibility for employers. It extends beyond adopting a POSH policy or constituting an Internal Committee (“IC”) and requires organisations to maintain an effective complaint redressal mechanism, conduct awareness programmes, preserve records confidentially and complete applicable reporting obligations. For employers, a structured POSH compliance calendar can help ensure that statutory requirements are addressed throughout the year rather than being treated as a year-end exercise. Periodic reviews of the IC, employee training, complaint records, annual reporting and corporate disclosures can also help identify gaps before they result in regulatory scrutiny or disputes. A well-maintained POSH compliance calendar should therefore identify the applicable statutory obligations, the person responsible for completing each task, the records required to demonstrate compliance and the relevant reporting deadlines. ## Understanding the POSH Compliance Framework The POSH Act requires employers to provide a [safe working environment](https://ksandk.com/labour-employment/women-night-shifts-osh-code-india/) and establish an appropriate mechanism for receiving and addressing complaints of sexual harassment. Under Section 4, an employer is required to constitute an IC at a workplace where the statutory conditions for its constitution are met, including the applicable threshold of ten or more workers. The Act also provides for a Local Committee to receive complaints in circumstances specified under the law, including where an establishment has fewer than ten workers or the complaint is against the employer. An IC must comprise a senior-level woman employee as the Presiding Officer, at least two employee members with the prescribed experience or knowledge, and one external member who meets the statutory eligibility requirements. At least half of the nominated members must be women. The Presiding Officer and every member may hold office for a period not exceeding three years from the date of nomination. These requirements make it necessary for employers to monitor the IC’s composition and functioning throughout the year. The appointment order alone is not sufficient if the committee subsequently develops vacancies, its members’ tenures expire or its composition no longer satisfies the statutory requirements. ## 2. POSH Annual Report: Contents, Responsibility and Filing Section 21 of the POSH Act requires the IC to prepare an annual report and submit it to the employer and the District Officer. Rule 14 of the Sexual Harassment of [Women at Workplace](https://ksandk.com/labour-employment/women-night-shifts-osh-code-india/) (Prevention, Prohibition and Redressal) Rules, 2013, prescribes the relevant reporting requirements. The annual report should capture the organisation’s POSH-related activities and complaint status for the relevant reporting period. The information includes: - The number of complaints of sexual harassment received during the year. - The number of complaints disposed of during the year. - The number of cases pending for more than 90 days. - The number of workshops or awareness programmes conducted. - The nature of action taken by the employer or the District Officer, as applicable. The report should be prepared using verified information from the IC’s complaint register, inquiry records, training records and action-taken documentation. The figures should be reconciled before submission so that the annual report accurately reflects the status of complaints and the action taken during the reporting period. ### Is 31 January the statutory deadline for POSH annual reporting? The POSH Act does not prescribe a single, universally applicable filing date for every establishment. However, 31 January is commonly followed as a reporting deadline in several jurisdictions and may be specified or communicated by the concerned District Officer or other competent authority. Employers should therefore verify the applicable deadline, prescribed format and mode of submission with the relevant District Officer and comply with any applicable local directions. A date followed in one district should not automatically be assumed to apply to every office or establishment across India. The absence of complaints during a reporting period should not be treated as a reason to disregard the annual reporting obligation. Employers should prepare the required report using accurate nil figures, where applicable, and follow the reporting requirements communicated by the competent authority. For organisations operating across multiple locations, the compliance calendar should identify the reporting authority, submission deadline and applicable procedure for each relevant establishment or jurisdiction. ## Internal Committee Review: Composition, Tenure and Accessibility The constitution and continued availability of the IC should be reviewed periodically. A committee that was validly constituted at the beginning of the year may require changes if a member leaves the organisation, changes roles, becomes unavailable or completes their tenure. Employers should review the following matters as part of their POSH compliance calendar: - **Presiding Officer:** Verify that the Presiding Officer continues to satisfy the statutory requirements, including the requirement relating to seniority. - **External member:** Confirm that the external member continues to meet the statutory eligibility requirements and remains available to discharge the role. - **Representation:** Ensure that at least half of the IC members are women. - **Tenure:** Track the tenure of each member and initiate reconstitution before a vacancy or expiry creates a compliance gap. - **Vacancies and changes:** Review resignations, transfers, departures and other circumstances that may affect the committee’s composition or functioning. - **Workplace coverage:** Assess whether the IC arrangements adequately cover the organisation’s offices and administrative units in accordance with the Act. - **Workplace notices:** Verify that the prescribed information, including the consequences of sexual harassment and the procedure for submitting complaints, is displayed at the workplace as required. Where a change in composition is necessary, the employer should issue an appropriate written order and update the relevant records and workplace notices. Any applicable registration or intimation requirements should also be checked against the directions of the competent authority. The IC’s contact details and complaint-submission procedure should be accessible to employees. An employer should not assume that the mere existence of an appointment order establishes that the complaint redressal mechanism is operational. ## POSH Training and Awareness: Planning Activities Throughout the Year Section 19 of the POSH Act places obligations on employers to organise workshops and awareness programmes for employees and orientation programmes for IC members, in accordance with the Act. Although the Act does not establish one uniform calendar date or a universal numerical quota of training sessions for all establishments, employers should maintain a planned and documented training programme that meets their statutory obligations. A practical training calendar may include: - **Employee awareness programmes:** Conduct periodic sensitisation sessions explaining prohibited conduct, the complaint mechanism, applicable procedures and the importance of maintaining a safe workplace. - **New employee induction:** Include POSH awareness in onboarding so that employees understand the organisation’s policy and reporting channels from the outset. - **IC orientation:** Provide role-appropriate training on the IC’s responsibilities, inquiry procedures, [confidentiality](https://ksandk.com/labour-employment/restrictive-covenants-employment-contracts-india/), impartiality and applicable timelines. - **Manager and HR awareness:** Familiarise managers, HR professionals and other relevant personnel with their responsibilities, including the appropriate handling and escalation of complaints. - **Refresher sessions:** Review whether additional training is warranted following policy changes, [organisational restructuring](https://ksandk.com/labour-employment/layoff-retrenchment-closure-industrial-relations-code-2020/), identified gaps or recurring issues. Training records should capture the date, subject matter, participants and other relevant details. Attendance records, presentation materials, communication circulated to employees and evidence of induction sessions can help demonstrate that the organisation has implemented and communicated its POSH framework. The frequency and format of training should be determined in light of statutory requirements, the organisation’s structure and its workplace-specific risks. Training should be treated as a continuing compliance responsibility rather than a one-time activity. ## POSH Record-Keeping and Confidentiality Accurate record-keeping is essential to demonstrate compliance with the POSH Act and to support the IC’s work. Employers should establish a documented process for maintaining records in a secure and appropriately restricted manner. Depending on the organisation’s activities and the circumstances of individual complaints, relevant records may include: - IC constitution and reconstitution orders. - The POSH policy and workplace notices. - Employee awareness and IC training records. - Complaint registers, acknowledgements and relevant reporting records. - Notices issued during an inquiry, statements and supporting documents. - Applications for interim relief and records of implementation, where applicable. - Inquiry findings, recommendations and action-taken records. - Annual reports, submission acknowledgements and applicable nil-report records. ### Confidentiality of POSH records Section 16 of the POSH Act restricts the publication, communication or making known of specified information relating to complaints and proceedings. This includes the identity and addresses of the aggrieved woman, respondent and witnesses, as well as information concerning conciliation and inquiry proceedings, recommendations of the IC or Local Committee, and action taken under the Act, subject to the statutory provisions.[1](#b83c275e-8afc-46a2-a554-1c1f4984c755) Employers should accordingly restrict access to complaint and inquiry records to authorised persons who require the information for legitimate purposes. Records should not be circulated through unrestricted internal email groups, shared drives or other channels that could expose confidential information. The POSH Act and the Central Rules do not prescribe one general retention period covering every category of POSH record. Employers should adopt a written retention and disposal schedule that considers applicable legal requirements, ongoing or anticipated proceedings, limitation periods, inspection requirements and information-security obligations. Any deletion or disposal process should be designed to avoid compromising confidentiality or the organisation’s ability to meet its legal obligations. ## POSH Disclosures in the Board’s Report In addition to the annual reporting requirements under the POSH Act, companies must consider the applicable disclosure requirements under the Companies Act, 2013 and the Companies (Accounts) Rules, 2014. The Companies (Accounts) Second Amendment Rules, 2025, notified on 30 May 2025 and effective from 14 July 2025, amended Rule 8(5) to require the relevant disclosures in the Board’s Report concerning: - The number of sexual harassment complaints received during the year. - The number of complaints disposed of during the year. - The number of cases pending for more than 90 days. Companies should verify the applicability of these disclosure requirements to their reporting obligations and ensure that the Board’s Report contains the required information. ### Reconciling POSH annual reports with Board’s Report disclosures The information reported under the POSH Act and the Companies Act should be reconciled before the relevant reports are finalised. The POSH annual report and the Board’s Report may be prepared with reference to different reporting periods, making it important to identify the period covered by each report and verify that the figures correspond to the relevant period.[2](#f036ec61-dc6a-4a22-8e9c-2944e0c64a18) A reconciliation process should check the number of complaints received, the number disposed of, cases pending beyond 90 days and the status of action taken. Any difference in the figures should be examined and explained internally before the Board’s Report is approved. This exercise is particularly important for companies with multiple offices, centralised HR functions or reporting systems that maintain complaint information separately for different business units. ## Consequences of POSH Non-Compliance Section 26 of the POSH Act provides for a penalty of up to ₹50,000 for an employer’s failure to constitute an IC, failure to take action required under specified provisions of the Act, contravention of the Act or Rules, or abetment of a contravention. A subsequent conviction for the same offence may attract double the punishment, in addition to the other consequences provided under Section 26, including potential cancellation, withdrawal or non-renewal of a licence, registration or approval required to conduct business, subject to the statutory conditions. The risks associated with non-compliance are not limited to monetary penalties. Gaps in the complaint redressal mechanism, incomplete records, inadequate confidentiality safeguards or failure to implement the IC’s recommendations may also expose an organisation to legal disputes, regulatory scrutiny and reputational harm. Common compliance gaps include failing to reconstitute the IC after a member’s departure, overlooking an applicable reporting deadline, maintaining inconsistent complaint figures, delaying required action or being unable to demonstrate that employees were informed of the complaint mechanism. A documented compliance calendar, supported by periodic internal reviews and clear responsibility for each task, can help employers identify and address these issues in a timely manner. ## 8. Practical POSH Compliance Calendar for Employers Employers can use the following framework to organise POSH-related responsibilities throughout the year. The schedule should be adapted to the organisation’s structure, applicable local requirements and reporting deadlines. | Frequency or trigger | Compliance activity | Records to maintain | | --- | --- | --- | | Quarterly or periodically | Review IC composition, tenure, vacancies, accessibility and outstanding compliance issues | Review checklist, updated IC records and action points | | On onboarding | Provide POSH policy information and induction awareness to new employees | Induction materials and attendance records | | At regular intervals | Conduct employee awareness programmes and IC orientation as required | Training calendar, attendance and materials | | Throughout the year | Maintain complaint, inquiry, interim relief and action-taken records | Restricted-access complaint and inquiry files | | Following changes in the organisation | Review IC composition, workplace coverage, policy communication and applicable registration requirements | Revised orders, updated notices and relevant filings | | Before annual reporting | Reconcile complaint figures, training information and action taken; prepare the annual report | Verified reporting data and annual report | | By the applicable local deadline | Submit the annual report to the employer and District Officer in accordance with the applicable requirements | Final report and submission acknowledgement | | During annual corporate reporting | Verify applicable Board’s Report disclosures and reconcile the relevant figures | Reconciliation statement and disclosure records | | Periodically | Review access controls, retention requirements and secure disposal procedures | Retention schedule and access-control records | The calendar should identify a responsible person or team for each activity, the internal completion date and the applicable statutory or local deadline. Where an organisation operates across multiple locations, the calendar should separately track location-specific requirements rather than assuming that a single filing process applies throughout India. ## Conclusion: Treat POSH Compliance as a Continuing Governance Responsibility The POSH annual report is not a stand-alone document. It is the outcome of a year-long process involving a properly constituted IC, employee awareness, appropriate complaint handling, confidential record-keeping and timely action on the committee’s recommendations. Employers should therefore treat POSH compliance as a continuing governance responsibility. A structured compliance calendar, periodic IC reviews, reliable reporting data and secure documentation can help organisations demonstrate that their complaint redressal mechanism remains accessible, effective and consistent with applicable legal requirements. The objective is not merely to complete an annual filing, but to maintain a workplace framework that supports the prevention and redressal of sexual harassment while protecting the confidentiality and procedural rights of the individuals involved. 1. Department of Expenditure, *The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013*, s 16 [https://doe.gov.in/files/inline-documents/DoE_Prevention_sexual_harassment.pdf](https://doe.gov.in/files/inline-documents/DoE_Prevention_sexual_harassment.pdf)   [↩︎](#b83c275e-8afc-46a2-a554-1c1f4984c755-link) 2. Department of Expenditure, *The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013*, s 16 [https://doe.gov.in/files/inline-documents/DoE_Prevention_sexual_harassment.pdf](https://doe.gov.in/files/inline-documents/DoE_Prevention_sexual_harassment.pdf)   [↩︎](#f036ec61-dc6a-4a22-8e9c-2944e0c64a18-link) *Last Updated on 24 October, 2026* Get King Stubb & Kasiva’s legal updates in your Google feed[![Add King Stubb & Kasiva as a preferred source on Google](https://ksandk.com/wp-content/uploads/google_preferred_source_badge_light_en@2x.png)](https://www.google.com/preferences/source?q=https://ksandk.com/) --- ## Office Locations - [New Delhi](https://ksandk.com/locations/top-corporate-law-firm-in-delhi/) (HQ): +91-11-41318190 | info@ksandk.com - [Mumbai](https://ksandk.com/locations/top-corporate-law-firm-in-mumbai/): 3 offices (Nariman Point, Lower Parel, Andheri) | mumbai@ksandk.com - [Bangalore](https://ksandk.com/locations/top-corporate-law-firm-in-bangalore/): bangalore@ksandk.com - [Chennai](https://ksandk.com/locations/chennai/): chennai@ksandk.com - [Hyderabad](https://ksandk.com/locations/hyderabad/): hyderabad@ksandk.com - [Pune](https://ksandk.com/locations/pune/): pune@ksandk.com - [Kochi](https://ksandk.com/locations/kochi/): kochi@ksandk.com ## Contact - [Contact Page](https://ksandk.com/contact-us/) - General: info@ksandk.com | +91-11-41318190 - WhatsApp: +91-7428567444 - [Privacy Statement](https://ksandk.com/privacy-statement/) - [Terms of Use](https://ksandk.com/terms-of-use/)