Annual POSH Reporting: A Comprehensive Guide for HR Managers and Directors

Introduction

The Sexual Harassment of Women at Workplace (Prevention, Prohibition And Redressal) Act, 2013 (“POSH Act”) ensures to prevent sexual harassment of women in workplaces, establish a safe and secure working environment, and provide structured mechanisms for complaint and redressal. 

For HR managers and directors, annual reporting under the POSH Act is far more than a mere procedural task; it is a significant compliance requirement and a profound ethical obligation. It is a key responsibility for HR professionals to ensure legal compliance, mitigate organisational risks, and actively cultivate a workplace culture that champions safety, dignity, and respect for all employees. 

Furthermore, annual POSH reporting extends beyond a simple “check-the-box” legal obligation. It serves as a strategic imperative that directly impacts organisational credibility, employee morale, and long-term reputation. The role of HR is not confined to merely submitting the report; it involves leveraging the reporting process as a potent instrument for continuous improvement and cultural reinforcement, thereby aligning legal compliance with broader business objectives.

The Framework

The submission of an Annual Report is mandated under Section 21 of the POSH Act. The said report is to be prepared by the Internal Committee (“IC”) or the Local Committee (“LC”) and submitted to both the employer and the designated District Officer.

Here are the key points to remember: 

• Rule 14 of the POSH Rules: Rule 14 of the POSH Rules, 2013, details the specific contents required in the annual report.
• Section 22 of the POSH Act: Beyond the IC’s report, Section 22 of the Act says that the employer must incorporate specific details regarding the organisation’s POSH compliance efforts into their own annual report, which is subsequently shared with the District Officer. 
• Companies Rules: Furthermore, for corporate entities, the Companies (Accounts) Second Amendment Rules 2025 mandate detailed POSH disclosures within their Board Reports, ensuring alignment with the obligations outlined in Sections 21 and 22, and Rule 14.
• Reporting Requirements: The POSH Act and its associated reporting requirements apply to all workplaces in India with 10 or more employees. This covers a range of entities, including public and private sector organisations, educational institutions, Non-Governmental Organisations (NGOs), and even informal settings. 

HR managers must recognise that annual POSH reporting is not a singular event but a multi-tiered compliance obligation integrated within a broader corporate governance framework. The Internal Committee’s annual report, mandated by Section 21 and detailed by Rule 14, serves as the fundamental data source. This data then directly informs the employer’s wider annual report, as per Section 22, and, for corporate entities, their statutory Board Report under the Companies (Accounts) Rules, 2014 (as amended in 2025). This interconnectedness means that any inaccuracies, omissions, or delays at the IC reporting level can have a cascading effect, which can ultimately lead to non-compliance at higher corporate reporting levels and significantly increase overall organisational legal and reputational risk. The role of HR is, therefore, significant in ensuring seamless data flow, accuracy, and consistency across all these mandated reports.

Mandatory Contents of the Annual POSH Report 

Rule 14 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, specifies the following (which shall be included in the said report):

• Number of complaints of sexual harassment received in the year: This refers to formal, written complaints filed by an “Aggrieved Woman” as defined by the Act.
• Number of complaints disposed of during the year: This includes cases that have been resolved through inquiry, conciliation, or even those that were withdrawn.
• Number of cases pending for more than ninety (90) days: This highlights cases that have exceeded the statutory inquiry timeline, requiring specific attention and explanation.
• Number of workshops or awareness programs against sexual harassment carried out: This includes all sensitisation efforts, such as workshops, seminars, and e-learning modules conducted for employees, managers, and IC members.
• Nature of action taken by the employer or District Officer: This summarises the disciplinary or other remedial actions implemented based on the inquiry findings.

Note: 

(a). Even if your organisation has not received any formal sexual harassment complaints throughout the year, submitting the annual report is still a must. In such instances, you will simply report “0” or “Nil” for the complaint numbers, but it is important to still include all the details about the awareness programs you conducted. Furthermore, if any cases were resolved through conciliation, be sure to include them in the Annual Report as “disposed complaints”. Similarly, any complaints that were formally filed and later withdrawn by the complainant should also be counted as “disposed cases” in your report.

(b). However, a complaint of sexual harassment needs to be in writing and made by the Complainant or authorised persons on their behalf. Therefore, oral and anonymous complaints are generally not to be included in the statutory Annual Report, as they do not meet the formal criteria for a complaint under the Act. 

Note: For every organisation, the ‘authorised person’ shall be the Director/ Promoter of the said organisation.

(c). While organisations may have internal gender-neutral policies for sexual harassment, the POSH Act specifically applies to complaints filed by an “Aggrieved Woman”. Consequently, complaints filed by men or individuals from other genders are typically not included in the annual report submitted.

Summary:

Data Point Required by Rule 14	Explanation & Key Considerations for HR
Number of complaints of sexual harassment received in the year	Include all formal, written complaints filed by an “Aggrieved Woman” as per the Act.
Number of complaints disposed of during the year	This includes cases resolved through inquiry, conciliation, or those formally withdrawn.
Number of cases pending for more than ninety days	Crucial for monitoring adherence to statutory inquiry timelines (90 days). Reasons for delay should be documented.
Number of workshops or awareness programs against sexual harassment carried out	Include all sensitisation efforts, such as workshops, seminars, and e-learning modules conducted for employees, managers, and IC members.
Nature of action taken by the employer or District Officer	Summarise the disciplinary or other remedial actions implemented based on the inquiry findings and recommendations.

The Annual Reporting Process: A Step-by-Step Guide

Step 1: Data Collection and Compilation

This step involves collecting credible statistics on the number of complaints received, including, those resolved, and those still pending. It also requires meticulous documentation of all awareness and training programs conducted throughout the year, including attendance records, completion certificates, or Management Information System (MIS) reports. 

All collected data must be rigorously double-checked against the organisation’s official records to verify accuracy. HR should implement data management strategies, treating every formal complaint, inquiry outcome, conciliation, withdrawn case, training session, and policy update as a significant data point to be precisely recorded. This continuous effort is not merely for annual reporting but serves as a risk mitigation strategy. 

Step 2: Report Preparation by the Internal Committee (IC)

The Internal Committee is primarily responsible for preparing the annual report for the calendar year of every organisation. While ideally all members of the IC should sign the report, it can also be signed by the Presiding Officer on behalf of the IC, provided that the IC has confirmed and “okayed” the Annual Report in writing or by way of an email. This ensures collective responsibility for the report’s contents. 

It is pertinent for HR to note that even if the organisation did not receive any formal complaints of sexual harassment during the year, the IC must still prepare and submit an annual report. In such instances, the number of complaints and other related data would be reported as “0” or “Nil,” but the report must still furnish details on the awareness programs and workshops conducted. 

Step 3: Review and Verification

Before the finalisation and submission of the annual report, the compiled data should undergo a thorough review and verification process. This includes cross-referencing the information with Internal Committee meeting minutes, individual inquiry reports, employee engagement records, and any policy updates made during the reporting period to ensure consistency and accuracy across all internal documentation. 

Step 4: Certification and Signatures

The prepared annual report must be formally certified for accuracy and completeness, and the said certification requires the signature of the Presiding Officer of the Internal Committee. Additionally, for the official filing, the report typically requires the organisation’s stamp/ letterhead of the organisation and the authorised person’s signature. 

Note: For every organisation, the ‘authorised person’ shall be the Director/ Promoter of the said organisation.

Step 5: Submission to the Employer and District Officer

The Internal Committee is required to prepare three (03) copies of the report: 

• one (01) for its own records, and 
• two (02) to be forwarded to the employer.

It is pertinent to note that, out of the 2 copies received by the employer, the employer retains 1 copy for their records and is responsible for forwarding the other copy to the designated District Officer. Ultimately, the employer bears the primary responsibility for filing the annual report with the District Officer. However, this responsibility can be delegated to an authorised person within the organisation. 

Note: For every organisation, the ‘authorised person’ shall be the Director/ Promoter of the said organisation.

Some of the key points to remember: 

• Filing with the District Officer: The annual report must be filed with the District Officer of the specific district where the organisation is located. Please note that the “District Officer” is an authority notified by the Appropriate Government, which could be the District Magistrate, Additional District Magistrate, or Deputy Collector. 
• Filing separate report: For organisations with multiple offices spread across different districts, it may be necessary to file a separate report for each district, and in some states, the report may also need to be filed with the concerned State Women and Child Development department. 
• Role of the HR Managers: HR managers can typically identify the relevant District Officer by consulting government websites (e.g., Ministry of Women and Child Development or State Government portals), reaching out to local labour departments for clarity, or seeking guidance from the external member of their IC.
• Submission of the Annual Report: The annual report can be submitted via courier or hand-delivery. If hand-delivered, it is imperative to obtain and retain an acknowledgement of submission for records. If couriered, the receipt of the courier should be retained. 

Step 6: Adhering to Deadlines

While the POSH Act itself is silent on a specific last date for submission, it is widely recommended that reports for the preceding calendar year (January 1st to December 31st) be submitted by January 31st of the following year. However, it is important for HR managers to actively monitor state or district-specific notifications, as submission deadlines can vary significantly. 

For HR managers, particularly those overseeing multi-state or multi-district operations, the “January 31st” deadline for POSH annual reports should be considered a general guideline, not a universal rule. The true compliance challenge lies in proactively monitoring and adhering to highly localised, state, and even district-specific notifications regarding submission deadlines and prescribed formats. 

Key Stakeholders and Their Responsibilities

Effective POSH compliance and accurate annual reporting are not the sole responsibility of any single entity but rather depend on an understanding of shared responsibilities and inter-dependencies among the Internal Committee, the Employer (primarily represented by HR and senior leadership), and the District Officer. 

The following is the breakdown of the responsibilities:

(A). Directors and Managers

Directors and managers play an important role in driving and upholding POSH compliance within the organization:

• Leadership Commitment: Top leadership must secure and demonstrate commitment to fostering a culture of respect and zero tolerance for harassment. They should actively participate in and endorse POSH initiatives, leading by example.  
• Policy Implementation and Endorsement: Directors and managers are instrumental in ensuring the POSH policy is not just drafted but effectively implemented and understood across all levels. 
• Awareness and Training Participation: They must be fully aware of the POSH Act’s provisions and their responsibilities. Managers and team leaders are specifically empowered to recognise and proactively address harassment issues within their teams. They should participate in and support regular POSH training for all employees, including themselves and their teams.  
• Resource Allocation: Leadership involvement ensures that requisite resources, such as training and specialised personnel, are available to preserve the integrity of the POSH policy and its implementation.  
• Board Report Disclosures: For corporate entities, directors are directly responsible for ensuring detailed POSH compliance disclosures within their Board Reports, including complaint statistics and workforce gender composition, as mandated by the Companies (Accounts) Second Amendment Rules, 2025.  
• Safe Culture: Directors and managers serve as role models and champions for POSH compliance, influencing attitudes and behaviours to build a genuinely safe, inclusive, and respectful workplace culture. They must avoid treating POSH as a mere “check-the-box” activity, as non-engagement from leadership negatively impacts employees. 

(B). Internal Committee (IC)

• Preparation of Report: The IC is primarily responsible for preparing the annual report for the calendar year.  
• Inquiry and Recommendations: The IC is mandated to conduct fair and transparent inquiries into sexual harassment complaints, typically within 90 days of receiving the complaint. Upon completion, it must submit its findings and recommendations for disciplinary action to the employer within 10 days.  
• Record Keeping: The IC is responsible for meticulously documenting all its meetings, proceedings, and case-related information, including cross-examination proceedings.  
• Confidentiality: IC shall ensure strict confidentiality regarding the identities of the complainant, respondent, witnesses, and all information related to the inquiry process.  
• Training: IC members require regular, specialized training to effectively understand their roles, powers, inquiry methodology, evidence handling, conciliation processes, and how to manage frivolous complaints.  

(C). Employer

• Ultimate Responsibility for Filing: While the IC prepares the report, the employer bears the ultimate responsibility for filing the annual report with the District Officer. This responsibility can be delegated to an authorised person within the organisation.  
• Policy and Awareness: Employers are legally mandated to establish a clear POSH policy, conduct regular awareness programs and sensitisation workshops for all employees, and prominently display notices about the policy and IC details.  
• Constituting IC: It is a statutory obligation for employers to constitute an Internal Complaints Committee for all workplaces with 10 or more employees.  
• Action on IC Recommendations: The employer must take appropriate action based on the IC’s inquiry report and recommendations, typically within 60 days of receiving the report.  

Conclusion

Annual POSH reporting is more than just a legal requirement; it is an important element for a safe and respectful workplace, and for HR leaders, it is not about checking a box, it is about following the law, being transparent, and building a positive company culture.

Think of the reporting process as having several layers. It starts with the Internal Committee gathering information, which then goes to the employer for official reports and finally to the company’s board. Everything needs to be perfectly coordinated and accurate. A small mistake at any stage can create bigger legal and reputational problems for the whole company. This is why HR and directors need to stay on top of data all year long, carefully tracking everything from complaints to training sessions.

While most people know the January 31st deadline, it is important for HR and the directors to watch out for specific deadlines in their state or district, as these can vary. Missing these deadlines can result in immediate penalties. 

Ultimately, the annual POSH report is a valuable tool for getting better. The data it provides, like trends in complaints or how well awareness programs are working, offers real insight. This helps companies improve their policies, make training more effective, and support their Internal Committee. Instead of just reacting to problems, organisations can work to prevent them.

YLCC would like to thank Nikunj Arora for his valuable insights into this article.