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Filing a Posh return is quick and easy, and can be done online with ngoministry.com in 3 simple steps.
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Think of it as an annual report card that an organization submits to the government to prove they are actively maintaining a safe, harassment-free workplace.
Any organization—including private companies, startups, NGOs, hospitals, and public sector units—that employs 10 or more people must form an Internal Committee (IC) and file this annual return.
The law keeps the data strictly numerical to protect confidentiality. You do not share names, specific case details, or identities. According to Rule 14 of the POSH Rules, the report must specify:
Complaints received: The total number of sexual harassment cases filed during the calendar year.
Complaints disposed of: How many cases were resolved or closed.
Pending cases: Any cases that have been open for more than 90 days.
Awareness programs: The number of workshops, employee sensitization sessions, and training modules conducted for the staff and IC members.
Action taken: The general nature of actions taken by the employer based on the IC's recommendations (e.g., termination, warnings, or suspensions).
The "Nil Report" Rule: Even if your organization had zero complaints and conducted all its training perfectly, you cannot skip filing. You must submit what is known as a "Nil Report" to show that you are actively compliant.
POSH compliance tracks the calendar year (January 1st to December 31st), not the financial year.
| Parameter | Details |
| Due Date | Generally on or before January 31st of the following year. |
| Who Prepares It? | The Internal Committee (IC) drafts and signs the report. |
| Who Submits It? | The Employer or an authorized HR/legal representative. |
| Submitted To | The local District Officer (DO) or the designated State Labour Department/Women's Commission. |
If your business has offices or branches spread across different districts or states, a centralized head-office filing is not enough. You must submit a separate POSH Annual Report to the respective District Officer of each specific district where your workplaces operate.
The government treats POSH compliance with a high degree of seriousness. Failing to file the return, filing late, or submitting incorrect data can result in:
A monetary penalty of up to ₹50,000 for the first offence.
Double penalties for repeated violations.
Severe actions like the cancellation or non-renewal of your business license if non-compliance becomes a habit.
A POSH Annual Report is the annual report prepared by the Internal Committee (IC) or Local Committee (LC) under Section 21 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
It contains prescribed information regarding sexual-harassment complaints, their disposal, pending cases, awareness programmes and action taken by the employer/District Officer.
Yes. Section 21 requires the Internal Committee or Local Committee to prepare an annual report every calendar year and submit it to the employer and the District Officer.
The responsibility rests primarily with the Internal Committee (IC) constituted under the POSH Act.
The report should ordinarily be prepared and authenticated by the Presiding Officer/Chairperson of the Internal Committee.
An employer of a workplace having 10 or more workers/employees is required to constitute an Internal Committee in accordance with the POSH Act.
Where the statutory conditions for an Internal Committee are not applicable, complaints may fall within the jurisdiction of the Local Committee constituted by the District Officer.
The Government of Delhi's POSH guidance also states that where an organisation has workplaces at different locations, the Internal Committee is to be constituted at each workplace as required under the Act.
The POSH Annual Report is based on the calendar year, i.e. 1 January to 31 December.
The principal provisions are:
Section 21 – Committee to submit annual report;
Section 22 – Employer to include information in its annual report; and
Rule 14 of the Sexual Harassment of Women at Workplace Rules, 2013 provides for the contents of the annual report.
Section 21 requires submission to the employer and District Officer, while Section 22 separately deals with disclosure in the organisation's annual report.
Rule 14 requires the Annual Report to contain, among other prescribed particulars:
Yes. The report should state the total number of sexual-harassment complaints received by the Internal Committee during the reporting year.
It refers to complaints in respect of which the Internal Committee has completed the prescribed process and the matter has been disposed of during the relevant year. The organisation should reconcile this figure with the IC's complaint register and inquiry records.
The Annual Report must disclose the number of cases pending for more than 90 days.
The organisation should maintain adequate records explaining the status of such cases and the reasons for pendency.
Yes. The report must contain the number of workshops or awareness programmes against sexual harassment conducted during the year.
It is therefore advisable to maintain records of:
No. The Annual Report is a statistical/compliance report and should not disclose the identity of the complainant, respondent or other confidential information relating to the proceedings. Confidentiality is particularly important in POSH proceedings.
Individual case narratives should generally not be included in the Annual Report. The report should contain the prescribed aggregate information rather than identifying details of particular complainants or respondents.
Under Section 21, the Internal Committee submits its Annual Report to:
The District Officer subsequently forwards a brief report on the annual reports received to the State Government.
The District Officer is the authority notified by the appropriate Government for the purposes of the POSH Act. The exact authority and filing mechanism can vary depending upon the State/UT and district in which the establishment is situated. Accordingly, organisations should verify the current instructions of the concerned District Administration before filing.
There is not one universally applicable central filing mechanism for every establishment under Section 21. The actual mode of submission may depend on the applicable State/UT or District Officer's instructions. Therefore, before filing, the organisation should verify whether the concerned District Administration requires physical submission or online submission.
The POSH Act requires the report to be prepared and submitted in the prescribed form and at the prescribed time. In practice, District Authorities commonly prescribe 31 January of the following year for the preceding calendar year's report. Organisations should nevertheless verify the current instructions applicable to their district before filing.
No. These are separate compliance requirements. The Internal Committee's Annual Report is prepared under Section 21.
Separately, Section 22 requires the employer to include the prescribed information regarding cases filed and their disposal in the organisation's annual report, where such annual report is required to be prepared.
Companies may have an additional disclosure obligation under the Companies Act framework concerning compliance with the requirement to constitute an Internal Committee.Accordingly, a company should separately review its Board's Report/annual-report disclosures in addition to preparing the IC Annual Report. The two compliances should not be treated as interchangeable.
Yes, it is advisable to submit a Nil Annual Report where no complaint was received during the year, rather than assuming that no filing is necessary.
The report can state, for example:
This provides documentary evidence of annual compliance.
No. Even where no complaint has been received, the employer should continue to comply with the preventive and institutional requirements of the POSH Act, including:
The Ministry of Labour and Employment has specifically emphasised creation of Internal Committees, timely handling of complaints and awareness regarding sexual harassment.
The organisation should maintain, as applicable:
Yes. The Internal Committee should maintain appropriate records of its meetings, proceedings and statutory activities. Such records can be important for demonstrating that the IC is functioning and not merely constituted on paper.
Yes. Training/orientation of IC members is an important component of effective POSH compliance. Although the Rule 14 annual-report requirement focuses on the prescribed reporting particulars, organisations should maintain evidence of IC training and awareness activities as part of their compliance records.
A pre-filing reconciliation should be undertaken to ensure that:
Failure to comply with the POSH Act can expose the employer to statutory consequences. Section 26 provides penalties for failure to comply with specified provisions of the Act. Depending upon the nature of the default, there can also be consequences relating to regulatory scrutiny and other statutory requirements.
Repeated or serious non-compliance can have additional consequences under the Act.
Potentially, yes. Section 26 contemplates consequences for certain non-compliance, including the possibility of consequences relating to licences, registrations or approvals where applicable. The precise consequence depends upon the nature of the default and the applicable statutory framework.
This requires careful examination of the organisation's workplace structure and the applicable IC/LCC arrangements.
Where an organisation has workplaces at different locations, the POSH Act framework requires appropriate complaint mechanisms at the relevant workplaces. The Government of Delhi's guidance, for example, states that an Internal Committee is to be constituted at every workplace where the statutory conditions require it.
Accordingly, organisations with multiple branches should not automatically prepare one consolidated report without checking the applicable requirements and District Officer arrangements.
The organisation should examine the location-wise POSH compliance requirements and the directions of the concerned District Officers.
A multi-location organisation may need to maintain location-wise IC records and reporting, particularly where separate workplaces/ICs are involved.
Yes, where the POSH Act applies to the workplace. The POSH compliance framework is not limited to ordinary commercial companies. Accordingly, NGOs, trusts, societies, Section 8 companies, educational institutions and other covered workplaces should examine their obligations under the Act.
The obligation depends upon whether the establishment falls within the applicable POSH framework and, in particular, whether an Internal Committee is required.
A small establishment that does not meet the statutory threshold for an Internal Committee may fall within the Local Committee mechanism.
Internal Committee (IC) is constituted by the employer at the workplace as required under the POSH Act while Local Committee (LC) is Constituted by the District Officer to receive and address complaints in circumstances covered by the Act, including complaints involving establishments where an Internal Committee is not constituted because the statutory conditions are not met.
The Government of Delhi describes the Local Committee as a mechanism particularly relevant for women in the unorganised sector and small establishments.
Ordinarily, the report is authenticated by the Presiding Officer/authorised representative of the Internal Committee, in accordance with the organisation's records and applicable filing requirements.
Where a District Officer prescribes a particular format or authentication method, that requirement should be followed.
Yes, where the competent District Authority provides an electronic filing mechanism.The organisation should use the currently prescribed portal, email or filing mechanism applicable to its district rather than relying on an outdated procedure.
A practical report may contain:
Part A – Organisation Details
Part B – Complaint Statistics
Part C – Awareness & Training
Part D – Action Taken
Part E – Declaration /Certification by the authorised/Presiding Officer.
The organisation should generally provide:
Yes, a consultant/Company Secretary/legal professional may assist the organisation in:
However, the statutory role and responsibility of the Internal Committee should not be substituted by an external consultant.
A professional firm can provide an integrated POSH compliance package covering:
1. POSH Compliance Audit
Review of the organisation's overall POSH framework.
2. Internal Committee Constitution
Assistance in constitution/reconstitution and documentation.
3. POSH Policy
Drafting/review and updating of the organisation's POSH policy.
4. Annual Report
Preparation and filing assistance for the Annual Report.
5. Training & Awareness
Employee sensitisation and IC orientation programmes.
6. Documentation
Maintenance/review of POSH registers, notices, records and compliance documentation.
7. Complaint Process Support
Procedural/legal assistance to the IC while maintaining confidentiality and independence.
8. Compliance Review
Periodic review of POSH compliance across branches and workplaces.
A practical annual compliance cycle can be structured as follows:
Period Key Activity
January–March Review previous year's compliance and IC composition
April–June POSH policy review and employee awareness
July–September IC training/orientation and compliance review
October–December Collect annual complaint and training data
December Final reconciliation of IC records
January Prepare and submit Annual Report for preceding calendar year
Throughout year Maintain complaint, inquiry, training and IC records
The Annual Report is only one component of POSH compliance.
A legally compliant organisation should also ensure:
Therefore, filing the Annual Report alone should not be treated as complete POSH compliance.
Section 26 provides for a penalty for failure to comply with specified provisions of the Act. For a first contravention, the Act provides for a fine which may extend to ?50,000.
The Act also provides for enhanced consequences for repeated contraventions, including potential consequences relating to licences, registrations or approvals, as provided by law.
Accordingly, organisations should treat POSH compliance as an ongoing statutory obligation rather than merely an annual filing exercise.
