POSH Act Compliance: Internal Committee Requirements for Employers

Any workplace with 10 or more employees must constitute an Internal Committee (IC) under the POSH Act (Prevention of Sexual Harassment of Women at Workplace Act, 2013) to receive and inquire into complaints. Non-compliance attracts a penalty of up to ₹50,000, with repeat violations risking business license cancellation.

Internal Committee composition requirements

• Presiding Officer: A senior woman employee (or appointed from another office if none is available at the same level)
• Minimum 2 employee members: Committed to the cause of women, with experience in social work or legal knowledge preferred
• 1 external member: From an NGO or association committed to women's issues, or someone familiar with sexual harassment matters
• At least half the total members must be women

What the IC must do

1. Receive complaints and conduct inquiries within the prescribed timelines (inquiry to be completed within 90 days)
2. Maintain strict confidentiality of all proceedings
3. Submit an annual report to the employer and the District Officer, including the number of complaints received and resolved
4. Conduct regular awareness and sensitisation training for employees

What employers must do beyond forming the IC

• Display the POSH policy and IC details prominently at the workplace
• Organise workshops and awareness programmes for employees
• Include POSH compliance in the annual Director's Report (for companies)
• Report annually on the number of cases filed and their status

What about offices with fewer than 10 employees?

These organisations don't need an Internal Committee but their employees can approach the Local Committee constituted by the District Officer — the obligation to provide a harassment-free workplace still applies.

Penalty for non-compliance

First violation: fine up to ₹50,000. Repeat violation: higher penalty and potential cancellation of business registration/license, in addition to reputational and legal exposure from unresolved harassment complaints.

Our HR compliance team helps set up a compliant Internal Committee and POSH policy for your organisation.