Common questions about POSH compliance
Answers to questions we hear most often from HR teams and in-house counsel on IC constitution, SHe-Box registration, training, timelines, and the statutory framework.
Do we need an Internal Committee?
Yes, if you have 10 or more employees. POSH Act 2013, s.4, requires organisations at or above this threshold to constitute an IC by written order. Employers with fewer than 10 employees are served by a Local Committee at the district level instead.
Can a lawyer serve as our external IC member instead of an NGO?
Yes. Section 4(2)(c) allows an external member who is either from an NGO committed to the cause of women, or a person familiar with issues relating to sexual harassment. The POSH Rules define that second limb to include a social worker with 5 or more years relevant experience or a person familiar with labour, service, civil, or criminal law — which a practising advocate meets directly.
Is POSH trainer certification government-recognised?
No. No government or statutory body in India certifies POSH trainers — every such certificate is private. Our trainers hold the NIST certification (National Institute of Skills Training), a private mark, which you can ask us to verify.
Is SHe-Box registration mandatory for us?
There is no single central mandate for all private organisations, but two separate routes can create the obligation. Territorially, the directives we can verify cover Delhi NCT (all public and private organisations), Gautam Buddh Nagar / Noida (10+ employees, April 2025), Mumbai City and Thane, and Maharashtra, Telangana, Odisha, Goa, Gujarat and Bengaluru Urban. Separately, if your sector's regulator requires SHe-Box registration of the entities it licenses, that obligation applies pan-India regardless of your district — and for a regulated entity it is usually the stricter one.
We have 12 employees — do we need an IC?
Yes. Twelve employees exceeds the 10-employee threshold in s.4, so you must constitute an IC by written order — a Presiding Officer (a senior woman employee), at least 2 employee members, and 1 external member, with at least half the committee women.
What is the complaint timeline?
A complaint may be filed within 3 months of the incident (s.9), extendable by a further 3 months. The IC must complete its inquiry within 90 days (s.11), and the employer must act on the report within 60 days (s.13).
When is the annual IC report due?
Many districts apply a 31 January deadline, but the Act and its Rules prescribe no single nationwide date (s.21). Confirm your District Officer's instruction rather than assume the January date applies to you.
What does an external IC member cost?
The POSH Rules require the employer to pay the external member ₹200 per day for IC proceedings, plus travel costs. That statutory allowance is separate from our professional fee for identifying, vetting, and appointing the member — see pricing.
What is the two-roster firewall?
We keep two disjoint rosters: advocates empanelled as external members on client Internal Committees, and case counsel who advise employers on live complaints. No individual appears on both, so the person adjudicating an inquiry is never the person who advised the employer on it. See the panel.
Can we deliver training online, or must it be onsite?
Both work. Online awareness and IC-capacity sessions suit distributed teams and are available pan-India; onsite delivery covers Delhi NCR. Either mode is designed to meet the s.19 awareness obligation.
How do we verify your panel members?
Use our verification page to request an advocate's Bar Council enrolment number or a trainer's roll number, along with the awarding body's own verification procedure, so you can confirm it independently.
What if we do not comply?
A first contravention attracts a penalty of up to ₹50,000 (s.26(1)). On a repeat offence, government may cancel a licence, registration, or approval (s.26(2)), and POSH disclosure is also required in the Board's Report under the Companies Act 2013.
Can one external member serve on more than one IC?
Yes. The POSH Rules expressly permit a person to serve as external member for more than one organisation, each under its own written appointment order and confidentiality undertaking. This is separate from our two-roster firewall, which keeps external members and case counsel on disjoint lists.
How often must the IC meet?
Frequency depends on complaint activity and your organisation's structure; the Act does not prescribe a fixed meeting schedule, though a committee must convene promptly once a complaint is received to meet the s.11 inquiry window.
Where to go next
The composition arithmetic at the smallest size that clears the s.4 threshold.
The three statutory clocks that start running, and where timelines slip.
Registration is a documents check, separate from constituting your IC.
Check this against the record
Everything on this page rests on the statute, the Rules, or a reported judgment. These are the originals — links open on the issuing body's own site.
The Government of India repository carrying the bare text of the POSH Act 2013 and its Rules.
The Ministry of Women & Child Development portal for IC registration and complaint tracking.
The ministry administering the POSH Act 2013 and the SHe-Box portal.