POSH compliance services in India: ICC setup, training, annual return and audit.
End-to-end POSH Act compliance for businesses with 10 or more employees. Regikart constitutes your Internal Committee, drafts the policy, trains employees, files the annual return on the SHe-Box portal and writes Board Report disclosures under the Companies (Accounts) Second Amendment Rules 2025.
4 Offices · CA + CS Led · 10+ Years · POSH-Compliant Setup in 7 Days · Pan-India coverage
Reviewed by CA & CS Team · Regikart · Verified for POSH Act 2013 and Companies (Accounts) 2025 Rules · Last updated 26 May 2026
Mandatory for every Indian workplace with 10+ employees.
Constitute an Internal Committee, draft a written policy, train employees, register on the SHe-Box portal and file an annual return by 31 January with the District Officer.
Penalty for default is up to Rs 50,000 under Section 26, plus Rs 3,00,000 on the company and Rs 1,00,000 per officer if Board Report disclosures are missed or false. Regikart handles the full cycle for fees starting at Rs 9,999.
| Item | Detail |
|---|---|
| Governing Act | Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 |
| Applicable To | Every workplace with 10 or more employees - private, public, NGO, school, factory, branch office |
| Annual Return Timeline | By 31 January following the calendar year being reported (Rule 14, POSH Rules 2013) |
| Cost (Regikart) | IC setup Rs 9,999 onwards; annual return Rs 4,999; training Rs 7,500 onwards per session |
| Penalty (Section 26) | Up to Rs 50,000 first default; doubled fine plus licence cancellation on repeat |
| Form and Portal | Form-A (Annual Report) to District Officer; SHe-Box portal at shebox.wcd.gov.in for IC registration and complaints |
| Authority | District Officer (District Magistrate or designated officer) under Section 5; Ministry of Women and Child Development |
Statutory duties every employer must discharge under the POSH Act 2013.
POSH compliance is the set of statutory duties an Indian employer must discharge under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. Section 4 requires every workplace with 10 or more employees to constitute an Internal Committee, adopt a written policy, train employees, display notices and file an annual return with the District Officer by 31 January each year.
Non-compliance under Section 26 attracts a fine up to Rs 50,000 for the first default and doubled fines plus cancellation of licence or registration on repeat default. Compliance is not optional even when no complaint is received - a nil return is still mandatory under Rule 14 of the POSH Rules 2013.
From July 2025, the Companies (Accounts) Second Amendment Rules 2025 require listed and unlisted companies to disclose complaint statistics and workforce gender composition in the Board's Report. The Ministry of Women and Child Development has also made SHe-Box portal registration mandatory for every workplace following Supreme Court directions issued in December 2024, August 2025 and January 2026.
Key terms you should know
Internal Committee (IC)
Statutory committee under Section 4 with a senior woman Presiding Officer, 2 internal members and 1 external member from an NGO. Term: 3 years.
Form-A (Annual Report)
Prescribed annual report format under Rule 14 of the POSH Rules 2013. Covers complaints received, disposed, pending 90+ days and training conducted.
SHe-Box Portal
Ministry of Women and Child Development portal at shebox.wcd.gov.in for IC registration and complaints. Launched 29 August 2024; mandatory from Dec 2024 SC order.
District Officer
District Magistrate or officer designated under Section 5. Receives Form-A filings, conducts surveys, takes penalty action under Section 26.
POSH applies to every workplace in India with 10+ employees.
The 10-employee threshold is counted per physical workplace under Section 4(2), not per legal entity. This is the most commonly misunderstood part of the Act.
| Employer Type | POSH Compliance Position |
|---|---|
| Private companies, LLPs, partnerships | Mandatory at any branch with 10 or more employees on payroll, contract or consultancy |
| Public sector and government departments | Mandatory; same 10-employee threshold per administrative unit |
| Schools, colleges, coaching centres | Mandatory; UGC norms may apply additionally for higher education institutions |
| Hospitals, clinics, hotels, retail outlets, warehouses | Mandatory; each branch with 10+ employees needs its own IC |
| NGOs, trusts, Section 8 companies, factories | Mandatory; no exemption based on entity type or gender mix of workforce |
Under Section 4(2), every administrative unit or branch with 10 or more employees needs its own Internal Committee. A company with a 15-employee Pune office, a 12-employee Gurugram office and an 8-employee Kolkata office must constitute two ICs - one each for Pune and Gurugram. The Kolkata office, being under 10, escalates complaints to the nearest IC or the Local Committee.
Six service modules covering the full POSH cycle.
1. Workplace Audit and Scoping
- Map every branch and administrative unit with 10+ employees.
- Verify whether existing ICs are properly constituted and within 3-year term.
- Check whether SHe-Box registration exists for each workplace.
2. Internal Committee Constitution
- Identify senior woman as Presiding Officer under Section 4(2)(a).
- Shortlist external member from NGO or women's rights professional panel.
- Issue formal appointment letters and Board resolution as required.
3. POSH Policy Drafting
- Policy aligned with 2013 Act, 2013 Rules and 2025 Companies Rules.
- Bilingual format (English plus one regional language) for branch display.
- Board adoption note and display poster pack under Section 19(b).
4. Employee and IC Member Training
- Mandatory awareness session for all employees under Section 19(c).
- Skill-building programme for IC members under Section 19(d).
- Attendance evidence pack and post-training quiz for compliance proof.
5. SHe-Box Registration
- Head office and each branch registered on shebox.wcd.gov.in.
- Upload IC member details, nodal officer details and policy.
- Update within 30 days on any IC composition change.
6. Annual Return and Board Report
- Form-A annual return to District Officer of every district where workplace is located.
- Board Report disclosure under Rule 8(3) of 2025 Companies Rules.
- Maternity Benefit Act 1961 compliance affirmation bundled with the disclosure.
Form-A under Rule 14 - five mandatory disclosures.
The annual POSH return is filed by 31 January for the preceding calendar year. Even a zero-complaint year requires a nil return - one of the most frequently penalised misses.
- Number of sexual harassment complaints received during the calendar year.
- Number of complaints disposed of during the year.
- Number of cases pending for more than ninety days, with reasons for delay.
- Number of workshops or awareness programmes carried out for employees, managers and IC members.
- Nature of action taken by the employer or District Officer where the IC made specific recommendations.
Common mistakes - and how Regikart prevents them
One IC at head office covering all branches
Section 4(2) requires an IC at every workplace with 10+ employees. We map every administrative unit and constitute branch-level ICs to close this most-cited inspection gap.
Skipping the annual return because no complaint was received
A nil return is still mandatory under Rule 14. We file Form-A annually with the District Officer to keep the compliance trail unbroken even in zero-complaint years.
IC operating beyond the three-year term
An IC with lapsed terms has no legal standing and any inquiry it conducts can be set aside. We track terms in the compliance calendar and trigger reconstitution before expiry.
Missing the 2025 Board Report POSH disclosure
Disclosing only IC constitution without the new 2025 complaint statistics triggers Rs 3,00,000 on the company and Rs 1,00,000 per officer under the Companies Act. We draft the full disclosure language coordinated with your auditor.
Six steps to a fully-compliant POSH program.
Regikart handles every step and produces evidence-grade documentation - so the next District Officer inspection or statutory auditor review is a non-event.
Workplace Audit
Map every branch and administrative unit with 10+ employees. Confirm whether existing committees are properly constituted, whether three-year terms have lapsed and whether SHe-Box registration exists.
IC Constitution
Identify a senior woman as Presiding Officer (Section 4(2)(a)), two internal members and one external member from an NGO. Issue formal appointment letters. Term: 3 years from appointment.
Policy Drafting and Board Adoption
Draft a POSH policy aligned with the Act, the 2013 Rules and the Companies (Accounts) Second Amendment Rules 2025. Get it approved by the Board and display at every workplace under Section 19(b).
Employee and IC Training
Conduct mandatory awareness sessions for all employees under Section 19(c) and a separate skill-building programme for IC members under Section 19(d). Maintain attendance evidence.
SHe-Box Registration
Register the head office and each branch on the SHe-Box portal (shebox.wcd.gov.in). Upload IC member details, nodal officer details and the policy. District Officers verify registration.
Annual Report Filing
Prepare Form-A under Rule 14 with complaint statistics, training records and IC composition. Submit to District Officer of every district by 31 January. Mirror disclosures in the Board Report.
What you share before we file
For IC constitution
- List of employees at each workplace with gender split.
- Profiles of proposed internal members and senior woman Presiding Officer.
- CV and consent letter of the proposed external member (NGO or social work background).
- Board resolution or HR head's appointment note authorising IC constitution.
For policy and SHe-Box
- Existing HR policy, employee handbook or code of conduct (if any).
- Company letterhead and authorised signatory details.
- List of branch locations and employee headcount at each.
- PAN and TAN of the entity; nodal officer name, designation and contact.
For annual return
- Complaint register maintained by the IC (even if nil).
- Minutes of IC meetings held during the calendar year.
- Training attendance records with dates, trainer name and topics covered.
- IC member appointment letters and any reconstitution orders during the year.
Modular pricing - pick what you need.
Six most-picked modules below. Inquiry support per complaint and multi-branch packages are quoted on call.
IC constitution (single workplace)
External member + appointment letters
Member sourcing, kick-off meeting, orientation note
IC constitution (additional branch)
Per additional workplace
Same scope as primary IC for each branch
Annual POSH return (Form-A)
Form-A to District Officer
IC register review, drafting, submission, acknowledgement
Employee awareness training
Up to 50 employees, in-person
Section 19 attendance pack + post-training quiz
Annual POSH audit
Documentation + IC + SHe-Box
Term verification, training audit, audit report
External member retainer
Empanelled external member
Covers up to 4 IC meetings annually
All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.
POSH external member sitting fee is Rs 200 per meeting under Rule 6 of the POSH Rules 2013, payable by the employer. Annual retainer engagements bundle this with the empanelled-member service.
Share your workplace size, branch count and current IC status - we come back with a scope-locked quote and timeline within 30 minutes during business hours.
Day-wise rollout plan with deliverables.
| Day | Activity | Output |
|---|---|---|
| Day 1-2 | Onboarding call; workplace audit; branch headcount mapping | Scoping note + fixed quote |
| Day 3-5 | External member shortlist for client approval; internal nominations finalised | IC composition note |
| Day 6-7 | Appointment letters issued; IC formally constituted; first meeting scheduled | Constitution order + Board resolution |
| Day 8-15 | Policy drafting; client review; Board adoption | Signed POSH policy + display posters |
| Day 16-20 | Employee training; IC orientation; SHe-Box registration | Training attendance pack + SHe-Box acknowledgement |
| By 31 January each year | Annual Return filing for previous calendar year | Form-A acknowledgement from District Officer |
IC constitution within 7 days, full policy and training rollout in 15-20 days, annual return filed by 31 January every year. Reconstitution alerts triggered 30 days before the 3-year IC term expiry.
Three things change with a CA + CS team on POSH.
CA and CS in one engagement
Combined CA and CS practice covering Companies Act disclosures, POSH Act filings and labour code overlaps - no juggling between three different advisers for one compliance.
In-house external member panel
Empanelled external members sourced from NGOs and women's rights professionals. No last-minute scrambling for the mandatory Section 4 external slot.
Tracked compliance calendar
Email and WhatsApp reminders 30 days before annual return due date. Term-expiry alerts for IC reconstitution. 100 percent accuracy standard on all filings.
“Regikart constituted our Internal Committee across our Pune head office and two branch offices within 10 days. Their CS team also identified that our previous policy had not been refreshed since 2019 and rewrote it to align with the 2025 Board Report disclosure rules.”
HR Head, mid-size manufacturing company, Pune (40 employees)
“We had received a notice from the District Officer for not having filed the POSH annual return for two consecutive years. Regikart filed the back returns and got the matter closed with a Rs 25,000 composition.”
Founder, IT services firm, Gurugram (22 employees)
“As a private limited company we now have to disclose POSH complaint statistics in our Board Report. Regikart's CS team handled the disclosure language and got our auditor's sign-off. Wrapped up in our AOC-4 filing timeline.”
CFO, fintech startup, Bengaluru (65 employees)
Kolkata (HQ) for West Bengal and Eastern India · Delhi for NCT · Gurugram for Haryana · Pune for Maharashtra and Western belt - District Officer filings happen with local jurisdiction knowledge.
CA + CS Led · 10+ Years · POSH-Compliant Setup in 7 Days · 100 percent accuracy on statutory filings
Two delivery models compared - line by line.
| Aspect | DIY / In-house HR | Regikart-Assisted |
|---|---|---|
| IC composition compliance | Often missing external member or proper Presiding Officer | Sourced from NGO panel; senior woman identified per Section 4(2)(a) |
| Branch-level IC mapping | One IC assumed sufficient | Each branch with 10+ employees gets its own IC under Section 4(2) |
| Annual return discipline | Skipped in nil-complaint years | Form-A filed every January, even for nil years |
| SHe-Box registration | Often missed | Head office and each branch registered; updates within 30 days |
| Board Report disclosure (2025 Rules) | Old format used; Rs 3,00,000 penalty risk | Full 2025 disclosure language coordinated with auditor |
| Term renewal tracking | Forgotten; IC operates with lapsed term | Compliance calendar triggers reconstitution before expiry |
The provisions that govern POSH compliance.
Section 4 - POSH Act 2013
Constitution of Internal Committee at every workplace with 10 or more employees. Presiding Officer must be a senior woman; one external member is mandatory.
Section 19 - POSH Act 2013
Employer duty to provide a safe environment, display notices, conduct training and treat sexual harassment as misconduct in service rules.
Section 21 and 22 - POSH Act 2013
IC prepares an Annual Report and submits to the employer and District Officer. Employer includes it in the Board Report or sends separately for non-companies.
Section 26 - POSH Act 2013
Penalty up to Rs 50,000 for first default. Repeated default doubles the fine and can lead to cancellation, withdrawal or non-renewal of business licence or registration.
Rule 14 - POSH Rules 2013
Prescribed contents and format of the Annual Report (Form-A): complaints received, resolved, pending 90+ days, training conducted, action on IC recommendations.
Rule 8(3) - Companies (Accounts) 2nd Amendment Rules 2025
Effective 14 July 2025. Board Report must disclose POSH complaint statistics, workforce gender composition and Maternity Benefit Act 1961 compliance affirmation.
Section 26 POSH Act: up to Rs 50,000 first default; doubled plus licence cancellation on repeat. Section 134 / 450 Companies Act 2013: Rs 3,00,000 on the company and Rs 1,00,000 on every defaulting officer for incorrect or omitted Board Report disclosure under Rule 8(3) of the 2025 Rules.
Regulatory authorities and portals: Ministry of Women and Child Development · SHe-Box Portal · Ministry of Corporate Affairs · India Code (POSH Act 2013).
POSH compliance - answered.
Questions, answered.
If you don't see your question here, write to us - a senior partner usually replies within a couple of business hours.
Still have questions?
Book a free 20-minute consult with a senior partner - we'll walk through your case and outline next steps.
Talk to a partner →Quick answers
- Q: Threshold for IC?
- A: 10 or more employees at any workplace - counting payroll, contract, interns, consultants.
- Q: Annual return deadline?
- A: 31 January each year for the previous calendar year (Rule 14).
- Q: Section 26 fine?
- A: Up to Rs 50,000 first default; doubled plus licence cancellation on repeat.
- Q: External member fee?
- A: Rs 200 per sitting under Rule 6; paid by employer.
- Q: IC term?
- A: 3 years from appointment; reconstitution mandatory on expiry.
What pairs well with POSH compliance
HR and compliance teams often need these adjacent engagements alongside POSH setup and annual return filing.
Payroll Outsourcing
Monthly payroll with EPF, ESI, PT, TDS and gender-split MIS for Board Report.
Income Tax Return Filing
ITR filing with linked CA review for individuals and businesses.
TDS Return Filing
Quarterly Form 24Q and 26Q filing for employers deducting tax at source.
Shop and Establishment
Foundational labour-law registration for any business hiring employees.
Get your POSH compliance set up before the next District Officer survey.
POSH compliance has moved from a paper exercise to an actively enforced workplace safety regime. The MWCD's SHe-Box portal, Supreme Court directions and the Companies (Accounts) Second Amendment Rules 2025 mean every employer with 10+ employees now has a verifiable, government-monitored compliance trail. The cost of getting it right is a small fraction of a Section 26 penalty or a District Officer notice.
Email [email protected] · Call · WhatsApp · Free scoping in 30 minutes during business hours.
Reviewed by CA & CS Team · Regikart · Last updated 26 May 2026 · Next review 26 August 2026 (Tier 1 - 90 days; POSH rules and SHe-Box portal evolve frequently)