The POSH annual report must be filed with your District Officer by 31 January every year. It has five mandatory fields: complaints received, complaints disposed, cases pending beyond 90 days (with reasons), action taken on ICC recommendations, and action taken where the employer disagreed with findings. Even if your ICC received zero complaints, you file a nil report. A ready-to-use template is included below.
Every employer with an Internal Complaints Committee (ICC) carries this obligation. For example, a garment factory in Tirupur with 45 workers has the same filing duty as a tech company in Whitefield with 2,000 employees. Miss the deadline, and you risk a fine of up to ₹50,000 under Section 26 of the POSH Act.
Key Takeaways
- Every employer with 10+ staff must file a POSH annual report to the District Officer by 31 January
- The report covers complaints received, disposed, and pending in the previous calendar year
- “Nil” reports are mandatory too: zero complaints still need formal filing
- Companies under the Companies Act must also disclose ICC data in their Board Report (Section 22)
- Non-filing can attract fines up to ₹50,000 under Section 26 of the POSH Act
Who Must File the POSH Annual Report?
If your organisation has constituted an ICC, you must file. Under Section 21 of the POSH Act 2013, the ICC prepares the report and submits it to the employer, who then forwards it to the District Officer.
Three categories of employers carry this obligation:
- Any employer with 10+ employees who has set up an ICC, including private companies, partnerships, proprietorships, trusts, and societies
- Companies registered under the Companies Act, 2013, which must also include ICC details in their annual Board Report under Section 22
- Government bodies and ministries, which file through the SHe-Box portal
For example, a hotel chain in Rajkot with three properties would need one report per branch if each branch has its own ICC. Across 30,000+ Attendo clients at Petpooja, we’ve noticed multi-branch businesses miss this filing most often.
Not sure whether you need an ICC? Check our guide on how to set up an Internal Committee under POSH.
What Is the POSH Annual Report Deadline?
The deadline is 31 January of each year. The report due on 31 January 2026 covers all complaints from 1 January 2025 to 31 December 2025. Unlike GST return deadlines, the POSH annual report deadline has no provision for late filing or extensions.
What the timeline looks like in practice
| Step | When | Who |
|---|---|---|
| Calendar year ends | 31 December | – |
| ICC prepares the annual report | First two weeks of January | ICC Chairperson |
| Employer reviews and signs | Third week of January | Employer / HR head |
| Report submitted to District Officer | By 31 January | Employer |
| Board Report inclusion (Companies Act firms) | Before AGM (typically by September) | Company Secretary |
Consider a scenario where an IT services firm in Noida has their ICC chairperson on leave through most of January. By the time the report gets drafted, it is already early February. The District Officer may accept it once, but there is no guarantee of leniency.
Citation capsule: The POSH annual report deadline is 31 January every year, covering the previous calendar year (1 January to 31 December). The Act does not provide any extension or grace period, and non-compliance from 1 February can attract penalties under Section 26.
What Should the POSH Annual Report Contain?
Section 21(1) of the Act specifies five data points your report must include:
- Number of complaints received during the calendar year
- Number of complaints disposed of (resolved) during the year
- Number of complaints pending beyond 90 days (with reasons for delay)
- Nature of action taken by the employer on ICC recommendations
- Nature of action taken on complaints where the employer disagreed with ICC findings
Many District Officers also expect the ICC chairperson’s name, whether the external member was in place for the full year, and details of POSH awareness programmes conducted.
Citation capsule: Section 21(1) of the POSH Act requires ICC annual reports to include five specific data points: complaints received, complaints disposed, cases pending beyond 90 days with reasons, action taken on ICC recommendations, and action taken on complaints where the employer disagreed with findings.
POSH Annual Report Template: Ready-to-Use Format
The Act specifies the data points but not a standard form. Below is a template that covers what the District Officer’s office typically expects.
Organisation Details
| Field | Details |
|---|---|
| Name of the Organisation | [Your company name] |
| Registered Address | [Full address] |
| Reporting Period | 1 January 2025 to 31 December 2025 |
| ICC Chairperson | [Name, Designation] |
| External Member | [Name, Organisation] |
| Total Employees (as on 31 December) | [Number] |
Complaint Summary
| Sr. No. | Particulars | Number |
|---|---|---|
| 1 | Complaints carried forward from previous year | _ |
| 2 | Complaints received during the year | _ |
| 3 | Complaints disposed of during the year | _ |
| 4 | Complaints pending as on 31 December | _ |
| 5 | Complaints pending beyond 90 days (with reasons) | _ |
Action Taken
| Sr. No. | Nature of Action | Details |
|---|---|---|
| 1 | Written apology directed | _ |
| 2 | Warning issued | _ |
| 3 | Reprimand or censure | _ |
| 4 | Transfer of respondent | _ |
| 5 | Suspension or termination | _ |
| 6 | Compensation awarded to complainant | _ |
| 7 | Deduction from salary of respondent | _ |
Signed by: [Employer Name], [Designation], [Date]
Most templates available online miss the “awareness programmes” section. While it is not in Section 21’s text, several states now include it in their District Officer formats.
Need to draft your POSH policy from scratch? See our guide on how to create a POSH policy for small businesses.
Board Report Disclosure for Companies Act Firms
If your business is registered under the Companies Act, 2013, Section 22 of the POSH Act mandates that your annual Board Report confirms that an ICC has been constituted, the company has complied with POSH provisions, and the number of complaints received along with their status.
This Board Report is filed with the Registrar of Companies (ROC) before the Annual General Meeting. The Ministry of Corporate Affairs (MCA) has flagged this in compliance advisories, and company secretaries now treat it as a standard checklist item.
Citation capsule: Under Section 22 of the POSH Act, companies registered under the Companies Act 2013 must include ICC compliance details in their annual Board Report filed with the Registrar of Companies before the AGM, covering ICC constitution status and complaint disposal data.
Where Do You Submit the POSH Annual Report?
Private employers: Submit to the District Officer of the district where your workplace is located. In most states, the District Magistrate or Collector holds this role.
Mumbai alone has two districts (Mumbai City and Mumbai Suburban), so a restaurant in Andheri files to a different office than a textile showroom in Fort.
Government organisations: File through the SHe-Box portal. Private employers cannot use SHe-Box for annual report filing.
Confused about who your ICC should cover? Read our guide on who is covered under the POSH law in India.
Five Common Filing Mistakes SMEs Make
1. Not filing a “nil” report. Zero complaints still need formal submission. The obligation is to file, not to have complaints.
2. Filing late because the ICC chairperson was busy. Start drafting by 15 December using data through November, then add December’s numbers in the first week of January.
3. Forgetting the external member detail. If your external member resigned mid-year and you did not appoint a replacement promptly, that gap needs disclosure.
4. Using a generic template without state-specific fields. Some states have their own prescribed formats. Always check your local District Officer’s office for their format.
5. Not keeping proof of submission. Keep a signed copy with the District Officer’s stamp, or a courier receipt with tracking details.
What Happens If You Do Not File?
Non-filing carries penalties under Section 26 of the POSH Act: a fine of up to ₹50,000, double penalties for repeat violations, and the District Officer can recommend cancellation of your business licence.
The National Commission for Women (NCW) has been increasingly active in monitoring POSH compliance since 2022, with suo motu inquiries into companies in manufacturing clusters in Surat, Ludhiana, and Tirupur. During due diligence for funding rounds or acquisitions, missing POSH annual reports raises red flags that can slow or derail deals.
Citation capsule: Under Section 26 of the POSH Act, non-filing of the annual report can attract fines up to ₹50,000 for the first offence, with double penalties for repeat violations. The District Officer can also recommend cancellation or non-renewal of the employer’s business licence.
For a detailed breakdown, read our guide on POSH Act penalties and consequences for non-compliance.
How Can SMEs Stay on Track?
Building a recurring process is the only reliable way to avoid last-minute scrambles. The annual report is part of a broader compliance cycle that includes ICC meetings, awareness training, and year-round record-keeping.
| Month | Task |
|---|---|
| January (first week) | Add December data to the draft report |
| January (third week) | Get employer sign-off |
| January (last week) | Submit to District Officer, collect acknowledgement |
| April | First POSH awareness session of the year |
| July | Mid-year ICC review meeting |
| October | Second awareness session |
| November | Check external member tenure, renew if expiring |
| December (mid-month) | Start drafting the annual report |
Using an attendance and HR system like Attendo (formerly Petpooja Payroll) helps you track employee headcount across branches in real time. When your staff count crosses 10 at any branch, you know that an ICC needs to be set up there, and that branch enters the annual report filing cycle.
Conclusion
Every employer with an ICC must file by 31 January. Start your draft in mid-December, use the template above, and always collect an acknowledgement from the District Officer’s office.
Frequently Asked Questions
Yes. A nil report is mandatory under Section 21. Fill in all complaint summary fields with zeros and submit to the District Officer by 31 January. Skipping it because “nothing happened” is itself a compliance violation.
Government organisations file through the SHe-Box portal. Private employers must submit to the District Officer’s office, which in most districts means physical submission.
The annual report goes to the District Officer and covers every employer with an ICC. The Board Report disclosure is additional, only for Companies Act firms, filed with the ROC before the AGM.
The ICC chairperson prepares the report, but the employer submits it to the District Officer and signs the final copy before 31 January.
The Act does not provide for an extension or grace period. The District Officer can impose a fine of up to ₹50,000 under Section 26. On repeat non-compliance, the fine doubles and the officer can recommend cancellation of your business licence.
