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PoSH compliance, done properly.
The Prevention of Sexual Harassment at Workplace Act is one of the few laws where most companies sincerely believe they comply and quietly do not. This practice exists to close that gap: the policy, the committee, the External Member, the redressal mechanism and the filing, not just the training video.
If you’re going through this yourself: we’re so sorry. This page was written to help employers set up their compliance, so it isn’t the right place to find support for what you’re facing, and you deserve support. The Government of India’s SHe-Box portal (shebox.wcd.gov.in) lets you raise a complaint, and the National Commission for Women is there to help too: online at ncw.gov.in, or on their 24×7 helpline, 14490.
Ethika Worklife Private Limited · This is not an insurance product. · PoSH advisory is a separate, standalone advisory service line.
The PoSH Act in five plain facts.
It protects every woman at the workplace, not just employees.
The Act covers women in any working relationship: permanent staff, contract workers, interns, trainees, even visitors. And “workplace” is read broadly: it reaches offsite work, work travel, and work-related communication, not just the office floor.
If you have 10 or more people, an Internal Committee is mandatory.
At 10+ employees, every employer must constitute an Internal Committee (IC) to receive and inquire into complaints. It needs a senior woman as Presiding Officer, at least two other members, and, crucially, one External Member with a background in women’s rights or the law. At least half the committee must be women. Below 10 employees, complaints go to the district’s Local Committee instead.
There is a fixed process, with clocks on it.
A complaint can be filed within three months of an incident (extendable in some cases). The IC’s inquiry must conclude within 90 days, and its report goes to the employer within 10 days after that. Confidentiality runs through the whole process by law.
Forming the committee is the start, not the finish.
Employers must also publish a PoSH policy, run awareness and training at regular intervals, display the consequences of harassment at the workplace, support the IC’s functioning, and file an annual report with the District Officer.
Non-compliance has a price.
A first breach can draw a penalty of up to ₹50,000; repeat breaches double it and can lead to cancellation or non-renewal of business licences. For companies, board reports now must also disclose complaint numbers.
Someone is finally checking, and it’s the government, on the Court’s orders.
The Supreme Court order
On 12 August 2025, in Aureliano Fernandes v. State of Goa, the Supreme Court set a six-week deadline for a district-wise survey, carried out by District Officers with Labour Commissioners supplying the lists of establishments, to verify which organisations have actually constituted Internal Committees, with the data onboarded to the government’s SHe-Box portal. The Court acted because the States had not complied with its earlier order of 3 December 2024.
We are not accusing anyone of anything. We are stating what was reported, and letting you judge how plausible zero is across a company’s entire workforce, year after year. Across those same 300 companies, reported complaints rose from 161 in FY14 to 1,729 in FY25, a 974% increase over the period. Reporting grows where the system works.
Source: Ashoka University’s Centre for Economic Data and Analysis (CEDA) and Business Standard, analysis of NSE-300 annual reports.
A company that has only run the course is not compliant.
PoSH exists at two depths. Awareness training for the workforce is one. It matters, and Section 19 requires the employer to build awareness. But compliance is the other depth: the policy, the properly constituted Internal Committee, the qualified External Member, the redressal mechanism, and the Section 21 filing.
An enormous number of Indian companies believe the annual training module discharges the obligation. It does not. And the gap between what they have and what the Act requires is exactly where the penalties bite.
Seven services. Together, they are compliance.
Policy drafting & review
A PoSH policy written for your organisation and reviewed against the Act and Rules, not a template with your logo on it.
IC formation
The committee constituted correctly under the Act, and supported through the year with minutes, records, and continuity when members leave.
External Member provision
A qualified External Member per Rule 4: the appointment that decides whether your inquiry survives. See plain fact 2 above.
IC training
Practical, interactive and tailored to your organisation. We ground the committee in the Act and then take them through a simulated inquiry, from intake and complainant handling to hearings, weighing evidence, and report writing. The practice run is where a committee learns not to mistake a delayed or inconsistent account for fabrication.
- Covers the key legal and procedural aspects of handling PoSH complaints
- Practical case studies and interactive discussions
- Helps IC members understand their roles and responsibilities
- Session duration customised to your requirements, from 1.5 hours up to 3, 4 or 8 hours, or as required
Employee awareness
Workforce awareness sessions and the in-app course. This is the Section 19 duty, delivered on-site or through the RISE wallet.
Annual report & filing
The Section 21 annual report prepared with the IC and filed with the District Officer, on time every year, with the records to show it.
SHe-Box registration
Registering your organisation and its Internal Committee on the government’s SHe-Box portal, increasingly relevant since the Supreme Court survey.
Three ways to engage. Fourteen states.
Project
A defined scope: constitute the IC, draft the policy, train the committee, file the report. Delivered and closed. For companies fixing the gap once, properly.
Retainer
The practice on call through the year: External Member, the filing, and a number to ring the day a complaint lands. For companies that want it handled continuously.
48-hour urgent
A complaint has landed and the committee is not ready. We engage within 48 hours.
Commercials are scoped and confirmed in writing per engagement.
A practice, not a portal.
Megha Kumari
Legal Associate
Soujanya Kulkarni
Legal Associate
First point of contact for any engagement is Talk to us, one route in, so nothing lands in a personal inbox and nothing gets lost.
What employers ask us first.
We’re at 8 employees. Do we need an Internal Committee?
Not yet. The IC obligation begins at ten employees. Below ten, complaints route to the District Officer’s Local Committee. But note what that means: the obligation exists either way, and the day you make the tenth hire, a statutory committee obligation attaches whether anyone in the company notices or not.
Who has to sit on the Internal Committee?
Under Section 4 of the PoSH Act, read with the Rules, every workplace with 10 or more employees must constitute an Internal Committee through a written order, with at least four members:
- Presiding Officer: A senior-level woman employee. If unavailable, she may be nominated from another office, unit, workplace, department or organisation of the employer, as prescribed.
- At least two employee members: Preferably committed to the cause of women, or having experience in social work or legal knowledge.
- One External Member: From an NGO/association committed to the cause of women, or a person familiar with issues relating to sexual harassment.
- At least 50% of the total members must be women.
The Presiding Officer and Members hold office for a term not exceeding three years.
This is not merely a paperwork requirement. A defect in the constitution of the Committee can affect the validity of the inquiry itself.
Our annual training is done. Are we compliant?
Not by itself. See the section above. Training discharges the awareness duty; compliance additionally needs the policy, the properly constituted IC, the qualified External Member, the redressal mechanism and the Section 21 filing. The honest test: if a complaint landed tomorrow, could your committee lawfully run the inquiry?
Can any lawyer be our External Member?
Eligibility is not automatic. Rule 4 lays down specific qualifications, and courts have voided whole inquiries where the External Member did not meet them. Check the appointment against Rule 4 specifically, not against seniority or a bare law degree.
What happens if we simply don’t comply?
Section 26 sets the penalty: a fine up to ₹50,000, doubling on repeat, and on repeat offences the cancellation, withdrawal or non-renewal of the licences the business needs to operate. Since the Supreme Court’s August 2025 order, whether committees are even constituted is being surveyed district by district, so the odds of non-compliance staying invisible are shortening.
Is this part of the RISE wallet?
No. The employee awareness course lives in the wallet’s Learning module; the advisory is a separate, standalone service line with its own engagements and its own contract.
Get it right before you need it to be right.
Every part of PoSH compliance is testable on one day only: the day a complaint lands. The policy, the committee, the External Member, the training: either they hold that day or they were paperwork. This practice exists so they hold.