Any employer with 10 or more employees is legally required to constitute an Internal Committee under the POSH Act, yet a surprising number of companies treat this as a one-time formality rather than an ongoing compliance obligation with real annual requirements.
Getting the committee composition right
- A senior woman employee as the Presiding Officer
- At least two employee members committed to the cause of women, with a demonstrated background in social work or legal knowledge preferred
- One external member from an NGO or association familiar with sexual harassment issues — not optional, and frequently the gap we find during compliance reviews
Training isn't optional, and it isn't a one-time session
Employers are required to conduct regular awareness programmes for employees, and separate training for Internal Committee members on how to conduct an inquiry. A single onboarding-day mention of POSH policy doesn't meet this obligation.
The annual report requirement most companies miss
Employers must file an annual report on the number of complaints received and resolved, either as part of their annual report or submitted separately to the relevant government authority. This is one of the most commonly missed POSH obligations, since it isn't tied to an active complaint.
Handling a complaint correctly, if one arises
The Act specifies strict timelines: the inquiry must typically be completed within 90 days of the complaint, with the employer required to act on the committee's recommendations within 60 days of receiving them. Missing these timelines creates legal exposure independent of the underlying complaint's outcome.