The annual report is the one POSH document that leaves your office every year. The policy, the committee order and the training records stay with you until someone asks for them. The annual report goes to a government officer, on a cycle, whether or not anything happened.
That makes it the easiest place for an inspector to start. If the report is missing, late, or its figures do not match the company's Board's report, the questions that follow will be about the rest of your framework too. This guide covers what the law actually requires, what it does not, and how to prepare the report so the figures hold together.
What the law says: section 21, section 22 and rule 14
Three provisions do the work.
Section 21(1) of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 says the Internal Committee or the Local Committee, as the case may be, shall in each calendar year prepare an annual report, in the form and at the time prescribed, and submit it to the employer and to the District Officer. Section 21(2) then requires the District Officer to forward a brief report on the annual reports received to the State Government.
Section 22 places a separate duty on the employer. The employer must include, in its own report, the number of cases filed, if any, and their disposal under the Act. Where the organisation is not required to prepare such a report, it must inform the District Officer of the number of cases instead.
Rule 14 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, notified by the Ministry of Women and Child Development as G.S.R. 769(E) on 9 December 2013, lists what the committee's annual report must contain. It is short, and that is the point: the report is a summary of numbers and actions, not a narrative of each case.
Contents of the POSH annual report
| Rule 14 item | What to report | Where the figure comes from |
|---|---|---|
| (a) Complaints received in the year | The number of complaints of sexual harassment received between 1 January and 31 December | The Internal Committee's complaint register, by date of receipt |
| (b) Complaints disposed of during the year | The number of complaints the committee concluded in the year, including ones received in an earlier year | Inquiry reports and settlement records under section 10 or section 13 |
| (c) Cases pending for more than 90 days | Cases where the inquiry has run beyond the 90-day period the Act allows for completing it | Register entries with no inquiry report 90 days after the complaint |
| (d) Workshops or awareness programmes held | The number of workshops or awareness programmes against sexual harassment carried out | Training attendance sheets, session dates and agendas |
| (e) Nature of action taken | The nature of action taken by the employer or the District Officer on the committee's findings | Employer's action records under section 13, and any action by the District Officer |
Rule 14 does not prescribe a printed form, so there is no single official template for private employers. In practice the report is prepared on the committee's letterhead or the employer's, signed by the Presiding Officer and members, and accompanied by a short covering letter from the employer.
Most employers also add identification details that the rule does not ask for but the District Officer will need: the legal name and address of the workplace, the number of employees, the date the committee was constituted, and the names and roles of the Presiding Officer, members and external member. Adding them costs nothing and prevents a query.
What not to include. Section 16 of the Act prohibits publishing the identity and address of the aggrieved woman, the respondent and witnesses, and the contents of the complaint and inquiry. The annual report gives numbers and the nature of action, never names or case facts.
Who prepares it and who receives it
The Internal Committee prepares it. Section 4 requires every employer to constitute an Internal Committee; workplaces that have no committee because they have fewer than 10 workers are covered by the Local Committee under section 6. The Internal Committee, not the HR team and not the company secretary, is the author of the annual report. HR or the compliance function can collect the data and do the drafting, but the committee signs.
One report per committee. Where offices or administrative units are located at different places, or at divisional or sub-divisional level, the proviso to section 4(1) requires a committee at each of them. An employer with three units and three committees therefore has three reports, each going to the District Officer of the district where that unit sits. Our POSH compliance in Kolkata page works through an example with units in three different districts.
The Local Committee prepares its own. The District Officer constitutes a Local Committee for each district under section 6. It hears complaints from workplaces with fewer than 10 workers, or where the complaint is against the employer. It too prepares an annual report under section 21. A small employer without an Internal Committee does not file a committee report of its own, but should still co-operate with the Local Committee and keep its records.
It goes to two places. The employer and the District Officer. The District Officer is the officer the state government has notified for the district under section 5, usually a District Magistrate, Additional District Magistrate, Collector or Deputy Collector. Some districts name a nodal office or a department to receive these reports. Confirm the receiving office before you send.
Due date: what the Act and Rules fix, and what they do not
Section 21 fixes the period: each calendar year, which means 1 January to 31 December. It says the report is to be prepared at such time as may be prescribed. Rule 14, however, prescribes only the contents. Neither the Act nor the Rules sets a calendar date by which the report must reach the District Officer.
This is why you will see different dates quoted online. Some state governments and district offices have issued their own instructions with a submission date for the previous calendar year's report. Where your district has issued one, that is the date to follow. Where it has not, the safe course is to file the report early in the new year, as soon as the calendar year's figures are final.
Two practical points follow from the calendar-year rule. First, the POSH report does not follow the financial year, so it will never line up with your audited accounts. Second, the Board's report, discussed below, does follow the financial year. The same register has to produce both sets of figures, cut at different dates.
Board's report disclosure under rule 8(5)(x)
For companies, the POSH figures also go into the Board's report under section 134 of the Companies Act, 2013. Rule 8(5)(x) of the Companies (Accounts) Rules, 2014 originally required only a statement that the company had complied with the provisions relating to the constitution of the Internal Committee.
The Companies (Accounts) Second Amendment Rules, 2025, notified by the Ministry of Corporate Affairs as G.S.R. 357(E) on 30 May 2025 and in force from 14 July 2025, expanded it. The Board's report must now also give, for the financial year:
- the number of complaints of sexual harassment received in the year;
- the number of complaints disposed of during the year; and
- the number of cases pending for more than 90 days.
The same amendment added a separate statement by the company on compliance with the provisions relating to the Maternity Benefit Act, 1961. Many companies now place the two statements together in the Board's report.
The three POSH figures mirror items (a) to (c) of rule 14, but for the financial year rather than the calendar year. A company preparing its Board's report for FY 2025-26 therefore needs complaints received, disposed of and pending for 1 April 2025 to 31 March 2026, across every Internal Committee it has. The Board's report is then attached to the financial statements filed in AOC-4, so the figures become part of the public record. Our annual ROC filing service prepares the Board's report alongside AOC-4 and MGT-7, and the private limited company annual compliance checklist shows where it fits in the year.
LLPs, partnership firms and proprietorships do not prepare a Board's report, so rule 8(5)(x) does not apply to them. Their POSH obligations under the Act, including the committee and the annual report, remain the same.
SHe-Box and the annual report
SHe-Box is the Ministry of Women and Child Development's Sexual Harassment electronic Box portal at shebox.wcd.gov.in. The current version was launched on 29 August 2024. The Ministry describes it as a centralised platform for registering and monitoring complaints, and a central repository of information on Internal Committees and Local Committees across government and private workplaces.
Employers can onboard their workplace and update their Internal Committee's details on the portal. A complainant can file a complaint through it, and the complaint is routed to the relevant committee, with a nodal officer able to monitor its progress.
Two things SHe-Box is not. It is not a substitute for constituting an Internal Committee: the committee still has to exist, with the composition section 4 requires. And it is not, on what the Ministry has published, a filing route that replaces the section 21 annual report to the District Officer. Keep the two separate. Update SHe-Box when your committee changes, and file the annual report with the District Officer as your district requires.
A complaint received through SHe-Box is still a complaint received in the year. Make sure it reaches the committee's register, so it is counted in the annual report and in the Board's report.
Nil reports: a year with no complaints
Section 21 applies in each calendar year. It does not say that a year without complaints is exempt, and rule 14 still has items to report in such a year: awareness programmes held, and the nature of any action taken. A nil report is therefore still a report.
A nil report should say plainly that no complaints were received, none were disposed of and none were pending, and then give the number of workshops or awareness programmes held. That last line matters. A nil report that also shows no training at all invites the question of whether employees knew how to complain.
The same applies to the Board's report. A company with no complaints should state the three figures as nil, rather than omitting the disclosure.
How to prepare and file the report: step by step
- Step 1: Close the register on 31 December. Count complaints received, complaints disposed of and cases older than 90 days with no inquiry report, for each committee separately.
- Step 2: Collect the training record. List each workshop or awareness session in the calendar year with its date and attendance. Committee-member training counts as well as employee sessions.
- Step 3: Record the action taken. For each disposed case, note the nature of the action the employer took on the committee's recommendation, without names or facts.
- Step 4: Draft the report. Use the five rule 14 heads, add the workplace and committee details, and have the Presiding Officer and members sign it.
- Step 5: Submit to the employer. The committee hands the signed report to the employer. Keep the employer's acknowledgement.
- Step 6: Submit to the District Officer. Use the mode your district has asked for. Where there is no instruction, send a signed copy with a covering letter to the District Officer's office and keep the receiving stamp or postal proof.
- Step 7: Carry the figures forward. For companies, recut the register for the financial year and give the three figures in the Board's report under rule 8(5)(x).
Keep the signed report, the covering letter and the proof of submission together for every year. If the appropriate government calls for information or inspects records under section 25, this file is the first thing it will ask to see.
Common mistakes
- Filing by financial year. The committee's report covers the calendar year. Using April to March figures produces a report for the wrong period.
- One report for the whole company. Each Internal Committee reports for its own unit, to its own district's District Officer.
- Skipping the nil year. No complaints does not mean no report.
- Naming people. Section 16 bars disclosure of identities and case contents. Give numbers and the nature of action only.
- Figures that do not reconcile. The Board's report and the committee reports come from the same register. If they cannot be reconciled for the overlapping months, an auditor or inspector will notice.
- Treating SHe-Box as the filing. Updating the portal does not replace the section 21 report.
- A committee that has lapsed. Members hold office for up to three years under section 4. A report signed by a committee whose term has run out shows a gap in compliance.
- Relying on a date from a blog. Ask for the circular. If your district has not issued one, file early in the year anyway.
Penalty for not complying
Section 26(1) of the Act makes an employer who fails to constitute an Internal Committee, fails to take action under sections 13, 14 and 22, or contravenes other provisions of the Act, punishable with a fine of up to ₹50,000. The failure to include the case figures in the employer's report under section 22 is named specifically.
For a company, an incomplete Board's report is a separate issue under the Companies Act. It is easier to prepare both from one register than to answer for either.
How Regikart helps
Our company secretaries set up and maintain the full POSH framework: the policy, the Internal Committee order with an external member, training, the complaint register and the annual report to the District Officer. Our POSH compliance service starts from ₹9,499, plus GST.
For companies, we prepare the rule 8(5)(x) disclosure from the same register as the committee reports, as part of the Board's report. If you are also reviewing the rest of your employment compliance, see our labour law compliance service and the payroll compliance checklist.
Frequently asked questions
Is the POSH annual report mandatory?
Yes. Section 21 of the POSH Act, 2013 requires every Internal Committee and Local Committee to prepare an annual report for each calendar year and submit it to the employer and the District Officer. Section 22 separately requires the employer to include the number of cases and their disposal in its own report.
What is the due date for the POSH annual report?
The Act fixes the period, which is each calendar year, but neither the Act nor rule 14 sets a calendar date for submission. Some states and districts have issued their own instructions with a date. Follow the instruction for your district; where there is none, file early in the new year once the figures are final.
What does the POSH annual report contain?
Under rule 14: the number of complaints received in the year, the number disposed of, the number pending for more than 90 days, the number of workshops or awareness programmes held, and the nature of action taken by the employer or the District Officer. It gives numbers, never names or case facts.
Do we file a POSH annual report if there were no complaints?
Yes. The Act does not exempt a year with no complaints. File a nil report showing no complaints received, disposed of or pending, and give the number of awareness programmes held in the year.
What must a company disclose in its Board's report about POSH?
Under rule 8(5)(x) of the Companies (Accounts) Rules, 2014, as amended by G.S.R. 357(E) with effect from 14 July 2025, a statement on the constitution of the Internal Committee plus the number of complaints received, disposed of and pending for more than 90 days in the financial year. The same amendment added a statement on compliance with the Maternity Benefit Act, 1961.
Does registering on SHe-Box replace the annual report?
No. SHe-Box is the Ministry of Women and Child Development's portal for complaints and for Internal Committee and Local Committee information. Keep your committee details updated there, and still submit the section 21 annual report to the District Officer.
We have offices in two cities. How many reports do we file?
One for each Internal Committee. Where you have a committee at each unit, each committee reports to the District Officer of the district where its unit is located. A single company can therefore file reports in several districts.
What is the penalty for not filing?
Under section 26(1), an employer who fails to constitute an Internal Committee, fails to act under sections 13, 14 and 22, or contravenes other provisions of the Act, is punishable with a fine of up to ₹50,000.
About the author
Regikart CS Team
Company Secretaries at Regikart. Want to discuss this in the context of your business?
