01
Who Must Comply
The 10-employee threshold, which industries are covered, how to count contract workers and interns. If you have 10 people working for you in any capacity, you're covered.
POSH Compliance Kit Free PDF for Indian Employers
ICC setup, anti-harassment policy, complaint process, annual return filing, and penalty reference. Everything the Sexual Harassment of Women at Workplace Act, 2013 requires from employers with 10+ employees. Updated June 2026.
- ICC composition checklist: Presiding Officer, 2 employee members, 1 external member
- Complete complaint and inquiry process with 90-day timeline (Section 11)
- Annual return template, record-keeping formats, and penalty reference table
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Petpooja presents
POSH Compliance Kit
For Indian Employers
7
Sections · PDF Kit
2026
What's Inside
Seven sections covering every part of POSH compliance.
02
ICC Setup Guide
Presiding Officer (senior woman), 2 employee members, 1 external member from an NGO or legal background. 50% women requirement. 3-year tenure limit. Full documentation checklist.
03
POSH Policy Template
Eight essential clauses your policy must include: definition per Section 2(n), complaint filing process, inquiry procedure, confidentiality, non-retaliation, and penalty for breach.
04
Complaint & Inquiry Process
Step-by-step from receiving a complaint to resolution. Conciliation option, formal inquiry within 90 days, interim relief, and post-inquiry actions. Every timeline referenced to the Act.
05
Employer Obligations
Ten mandatory items under Section 19: constitute ICC, display policy, conduct annual training, provide safe environment, treat harassment as misconduct, file annual return.
06
Annual Return & Records
File with District Officer by 31 January. What to report: complaints received, disposed, pending beyond 90 days. Plus record-keeping formats and retention rules.
07
Penalties & Common Mistakes
₹50,000 fine for first offence. Licence cancellation on repeat. Seven common mistakes Indian businesses make, from missing ICC setup to forgetting the annual return.
Why This Matters
POSH Isn't Just for Corporates
Here's what catches most small business owners off guard: the POSH Act applies to every workplace in India with 10 or more employees. Restaurants, retail shops, clinics, salons, factories. No exemptions.
The Act has been in force since December 2013. But honestly, awareness among SMEs is still shockingly low. Most owners assume it's a "big company" requirement. It isn't. A salon in Pune with 12 staff needs an Internal Complaints Committee just as much as an IT company in Bangalore with 5,000 employees.
"Employees" under the POSH Act includes everyone: permanent, temporary, contractual, daily wage, interns, and even volunteers. A restaurant with 6 permanent staff and 5 delivery riders on contract has 11 employees. That's above the threshold.
The penalties are real. ₹50,000 fine for the first violation under Section 26. That stings, but the second offence is what hurts: the authorities can cancel your business licence or registration. Your shop, restaurant, or clinic can be forced to shut down.
Labour inspectors now routinely check POSH compliance during inspections. They ask three simple questions: Do you have an ICC? Where's your POSH policy displayed? Show me your last annual return. Most businesses can't answer even one of these.
This kit gives you everything to fix that. ICC composition and documentation, a ready-to-use policy with all mandatory clauses, the complete complaint handling process, and the annual return filing checklist. Seven sections, printable, and written in plain language.
Sample Preview
A quick look at what's inside the kit.
Here's a preview of what you'll get:
ICC Composition: Presiding Officer (senior woman employee), minimum 2 employee members, 1 external member (NGO/legal), at least 50% women. 3-year maximum tenure per member.
Complaint Timeline: Written complaint within 3 months of incident. Copy to respondent within 7 working days. Respondent reply in 10 working days. Inquiry completion within 90 days.
Employer Obligations: 10 mandatory items under Section 19, including ICC constitution, policy display, annual training, FIR assistance, and non-retaliation monitoring.
Penalty Table: ₹50,000 first offence (S.26), licence cancellation on repeat, ₹5,000 for confidentiality breach (S.16).
Annual Return: File with District Officer by 31 January. Report complaints received, disposed, pending beyond 90 days, and training conducted.
... plus a ready-to-use policy template with all 8 mandatory clauses and Section references.
Key Stats
Numbers every employer should know.
10+
Employee threshold for mandatory ICC constitution. Count everyone: permanent, temporary, contractual, daily wage, interns, and volunteers. Each branch with 10+ needs its own ICC.
Source: POSH Act 2013, Section 4(1)90 days
Statutory deadline to complete an inquiry from the date of complaint. Delays beyond 90 days must be reported in the annual return and can be challenged legally.
Source: POSH Act 2013, Section 11(4)₹50K
Maximum penalty for first-time non-compliance: not constituting ICC, not filing annual return, or not acting on ICC recommendations. Repeat offence: licence cancellation.
Source: POSH Act 2013, Section 26
Common Mistakes
5 POSH Compliance Mistakes SMEs Make
01
No ICC constituted at all
The most basic violation, and the most common among small businesses. ₹50,000 fine on first offence. Second time? Licence cancellation. If you have 10+ employees of any type, you need an ICC. Period.
02
ICC without an external member
Section 4(2)(c) requires one member from an NGO or a person with legal knowledge who isn't an employee. Skip this, and the entire ICC is invalidly constituted. Every inquiry it conducts can be challenged.
03
No annual POSH training conducted
Section 19(b) requires awareness programmes for all employees. Annual training isn't optional. New joiners need orientation. Existing staff need a refresher. ICC members need separate training on inquiry procedures.
04
Annual return not filed with District Officer
Due by 31 January every year. Covers the previous calendar year. Here's what most employers don't know: even if you received zero complaints, you must still file a nil return. No return filed = non-compliance.
05
Complaint process not documented or visible
Employees don't know who the ICC members are, how to file a complaint, or what happens after they file. The policy must be printed and displayed at a conspicuous place. A PDF buried on the shared drive doesn't count.
Make your workplace POSH-compliant.
Download the free POSH Compliance Kit. ICC setup, policy template, inquiry process, annual return checklist.
FAQ
Frequently asked questions.
Who needs to comply with the POSH Act?
Every employer in India with 10 or more employees must constitute an Internal Complaints Committee (ICC) under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. This applies to all industries: restaurants, retail, healthcare, manufacturing, IT, construction. The employee count includes permanent, temporary, contractual, daily wage, interns, and volunteers. Our detailed guide on POSH coverage explains the full scope.
What is the Internal Complaints Committee (ICC)?
The ICC is a mandatory body that receives and investigates sexual harassment complaints at the workplace. It must have a Presiding Officer (senior woman employee), at least 2 employee members, and 1 external member from an NGO or with legal expertise. At least 50% of ICC members must be women. Members serve a maximum 3-year tenure under Section 4(3). Read our guide on ICC vs LCC to understand which committee applies to your business.
What happens if my business doesn't have an ICC?
First offence: fine up to ₹50,000 under Section 26(1) of the POSH Act. Second offence: double the penalty plus potential cancellation of your business licence or registration under Section 26(2). Labour inspectors routinely check for POSH compliance during workplace inspections. Not having an ICC is the most common violation found. See our POSH complaint process guide to understand what happens once an ICC is in place.
How do I file the POSH annual return?
File with the District Officer of your area by 31 January every year, covering the previous calendar year. The return must include: total complaints received, complaints disposed of, cases pending beyond 90 days, whether awareness programmes were conducted, and the nature of action taken. Even if zero complaints were received, you must file a nil return. The format varies by state, so check with your local District Women and Child Development office. POSH is one of many compliance tasks; our labour law compliance checklist covers all the others, and the free statutory bonus calculator handles another common deadline.
Does the POSH Act apply to contract workers and interns?
Yes. Section 2(f) defines "employee" broadly to include anyone working at the workplace, whether for remuneration or not. This covers contract workers, temporary staff, interns, apprentices, and volunteers. The principal employer (not the staffing agency) is responsible for POSH compliance for contract workers at their premises. Your HR policy should explicitly state this coverage to avoid confusion.
About Petpooja
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