# POSH Compliance — Internal Committee & Policy

> Every employer with 10 or more employees must constitute an Internal Committee under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — chaired by a senior woman employee, with at least half its members women, and one external member from an NGO or with relevant experience. The employer must adopt a policy, run awareness programmes, and file an annual report. Non-compliance can be fined up to ₹50,000, with higher penalties and licence cancellation for repeat violations.

Practice: Labour Law & HR Compliance — https://www.industax.com/services/labour-hr/

Committees often exist on paper only; what protects an organisation is a functioning process — trained members, a clear complaint mechanism, confidential inquiries within the 90-day timeline, and documented outcomes.

We draft the policy, help constitute the committee with an external member, train members and employees, and prepare the annual report and the disclosure in the board's report for companies.

## Key facts

| Item | Detail |
| --- | --- |
| Applies | Employers with 10+ employees |
| Committee | Presiding officer (senior woman), ≥ 50% women, one external member |
| Inquiry timeline | Within 90 days |
| Annual report | To the District Officer |
| Penalty | Up to ₹50,000; higher for repeat violations |

## Who needs this

- Companies, LLPs and firms with 10+ employees
- Startups scaling teams
- Companies disclosing POSH in board reports

## What's included

- Policy drafting
- Committee constitution
- Training sessions
- Annual report

## Documents

- Employee strength by location
- Proposed committee members
- Existing policies

## Process

1. **Constitute** — Committee and policy in place.
2. **Train** — Members and staff trained.
3. **Report** — Annual report filed.

## FAQs

### Do remote-first companies need an Internal Committee?

Yes, if they have 10 or more employees. The workplace includes places visited during work and remote working arrangements.

### Must the external member be a lawyer?

No. The external member must be from an NGO or association committed to women's causes, or a person familiar with sexual harassment issues; many are lawyers or HR professionals.

### Is POSH disclosure required in the board's report?

Yes. Companies must state in the board's report that they have complied with constituting the Internal Committee under the Act.

## Official sources

- Ministry of Labour & Employment — Labour Codes: https://labour.gov.in/

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Canonical page: https://www.industax.com/services/labour-hr/posh-compliance
Publisher: Indus Tax — CA-led tax and compliance firm (https://www.industax.com). Contact: info@industax.com, 9059139258.
This is general information, not advice for your specific facts.