POSH annual report filing service — s.21 and Rule 14
Every Internal Committee must prepare an annual report for each calendar year and submit it to the employer and the District Officer (s.21). The report states the complaints received, disposed of and pending for more than 90 days, the awareness programmes held and the action taken (POSH Rules, rule 14). It is due even in a year with no complaints. The Act and Rules fix no single national due date. We prepare the report with your Committee in the Rule 14 format and handle the submission, within up to 30 working days, for ICs already constituted under s.4.
Does this apply to us?
No complaints received this year
A nil return is still required — the reporting obligation does not depend on there having been a complaint to report.
Multiple branches
Each office or administrative unit constitutes its own IC, so reports are compiled and filed per branch, not once for the whole organisation.
IC term expired mid-year
The reporting obligation continues; who signs the report for a Committee mid-transition is confirmed at scoping.
Newly covered employer
An employer that has just crossed the 10-employee threshold owes a first annual report for the period since IC constitution; the exact cut-off is confirmed at engagement.
Fewer than 10 employees
Employers below threshold, served by a Local Committee rather than an in-house IC, are not the audience for this service.
What we deliver
Report preparation, submission to the District Officer, and nil returns where no complaints were received. Delivered onsite across Delhi NCR and cities within about 300 km of Noida (elsewhere in India as required) or online pan-India, in English or Hindi. Turnaround is up to 30 working days; report format is confirmed at scoping.
The Act and its Rules fix no due date; districts set their own, and we confirm yours at scoping rather than assume one. See district practice below.
What the annual report must contain (Rule 14)
| Item | Rule | Where it comes from |
|---|---|---|
| Number of complaints of sexual harassment received in the year | r.14(a) | Committee's complaint register |
| Number of complaints disposed of during the year | r.14(b) | Reports under s.13, settlements under s.10 |
| Number of cases pending for more than ninety days | r.14(c) | Register, measured against s.11(4) |
| Number of workshops or awareness programmes against sexual harassment carried out | r.14(d) | Training records under s.19(c) |
| Nature of action taken by the employer or District Officer | r.14(e) | Employer's action under s.13(4) |
Section 21(1) says the report is prepared "in such form and at such time as may be prescribed". Rule 14 prescribes the five items above and nothing more: the Rules carry no form for the report and no date for it.
POSH annual report format: an outline you can work from
Rule 14 fixes the contents, not the layout. The outline below puts the five prescribed items in the middle and marks everything else as what it is: identification and sign-off that help the District Officer match the report to your Committee, but that no rule requires.
| Part | What goes in it | Basis |
|---|---|---|
| A · Identification | Name and address of the office or administrative unit the Committee serves; the employer; the date of the written order constituting the Committee, and its members | Not prescribed. Each office has its own Committee (s.4(1)), so name the one reporting |
| B · Period | 1 January to 31 December of the year reported on | s.21(1): "in each calendar year" |
| C · Complaints received | Number received in the year | r.14(a) |
| D · Complaints disposed of | Number disposed of during the year | r.14(b) |
| E · Pending over 90 days | Number of cases pending for more than ninety days | r.14(c) |
| F · Awareness programmes | Number of workshops or awareness programmes carried out; dates and audiences make the figure checkable | r.14(d) |
| G · Action taken | The nature of action taken by the employer or the District Officer, described without identifying the parties | r.14(e); confidentiality, s.16 |
| H · Sign-off | Signature of the Presiding Officer and members, with the date; a note of when it went to the employer and the District Officer | Not prescribed. Records that s.21(1) was complied with |
Where your district or the SHe-Box portal asks for its own format, use it, and make sure it still carries the five Rule 14 items. Gurugram's District Officer, for example, asks for reports "as per the attached checklist" published on its page.
Where to submit the POSH annual report, and to whom
- 01
To the employer
The Committee submits its report to the employer (s.21(1)).
- 02
To the District Officer
And to the District Officer of the district (s.21(1)): the District Magistrate, Additional District Magistrate, Collector or Deputy Collector whom the State Government has notified to act under the Act (s.5). The District Officer forwards a brief report on all the annual reports received to the State Government (s.21(2)).
- 03
Into the employer's own annual report
Separately, the employer includes the number of cases filed and their disposal in its own organisation's annual report or, where it prepares none, tells the District Officer the number (s.22). For a company, that is now the Board's Report disclosure under rule 8(5)(x); see the comparison below.
By what channel. The Act doesn't prescribe one. The SHe-Box portal has a feature for a workplace's Nodal Officer to submit the annual report to the District Officer digitally, and the Ministry's FAQ says the Nodal Officer "is required to update Annual reports on the portal". Some districts also name their own channel. See is SHe-Box registration mandatory?
Several offices. Each office or administrative unit has its own Committee (s.4(1)), so each Committee prepares and submits its own report. Where offices sit in different districts, confirm each district's channel separately.
Nil reports: a year with no complaints
Section 21 requires a report "in each calendar year", whether or not there were complaints. A nil report states zero against complaints received, disposed of and pending over 90 days (r.14(a)–(c)), and still lists the awareness programmes held (r.14(d)). Write the zeros in; a blank line reads as a missing figure, not a nil one.
A nil report with no awareness programmes either is worth a second look before it goes out: the employer's duty to run them at regular intervals (s.19(c)) doesn't depend on there being complaints.
Due dates and channels are set by districts
Because the Rules set no date, districts that want the reports set their own, along with the channel and sometimes the format. Gurugram's District Officer asked for reports for calendar year 2025 by 28 February 2026, accepted only by email from the organisation's official address, in line with a checklist the district published. Your district's date, if it has set one, may be different.
None of these dates is a statutory deadline, and a date that applies in one district does not carry over to the next. We find out your district's date, channel and format at scoping, and plan the year's report around it.
Annual report vs the Board's Report disclosure
| POSH annual report | Board's Report disclosure | |
|---|---|---|
| Law | POSH Act s.21, Rules r.14 | Companies (Accounts) Rules r.8(5)(x), (xiii) |
| Who | Every Internal Committee | Companies, through the Board |
| Period | Calendar year | Financial year |
| Goes to | Employer and District Officer | Shareholders; Registrar with AOC-4 |
| Contains | Complaints, awareness programmes, action taken | IC compliance statement, three complaint counts, Maternity Benefit statement; headcount by gender in the e-form |
The numbers won't match between the two, because the periods differ. See POSH disclosure in the Board's Report.
The statutory basis
| Fact | Statute |
|---|---|
| The IC prepares an annual report and submits it to the employer and the District Officer. | s.21, Rule 14 |
| Each office or administrative unit constitutes its own IC, and therefore its own report. | s.4 |
| POSH disclosures, including complaint counts, are required in the Board's Report of companies. | Companies (Accounts) Rules r.8(5)(x) |
| Penalty for a first contravention of the Act. | s.26(1) — up to ₹50,000 |
| On a repeat offence, government may cancel the relevant licence, registration, or approval. | s.26(2) |
Who delivers it
Reports are prepared by our compliance team from your Internal Committee's records, for the Committee to adopt and sign. How the external-member panel is constituted is set out on the panel page.
Price
Confirmed at scoping — depends on number of branches and whether the IC's records are complete. Full pricing detail is at pricing.
What we do not do
- We do not constitute your Internal Committee as part of this service; that is a separate engagement under Internal Committee formation.
- We do not represent your organisation before the District Officer in a dispute over a filed report; contentious matters are handled under case support.
- We do not control the District Officer's acknowledgment timeline once a report is submitted.
- We do not invent a single nationwide filing date where none is prescribed by the Act or Rules — the applicable district practice is confirmed, not assumed.
- We do not file on behalf of an IC that has not been validly constituted by written order.
Frequently asked
What is the POSH annual report?
It is the report every Internal Committee must prepare for each calendar year under s.21 of the POSH Act and submit to the employer and the District Officer. Rule 14 of the POSH Rules sets what it contains: complaints received, disposed of and pending over 90 days, awareness programmes held, and action taken.
Is the POSH annual return the same as the annual report?
Yes. "Annual return" is a common name for it; the Act calls it an annual report (s.21). It is a different filing from the POSH disclosure a company makes in its Board's Report.
Where do we submit the POSH annual report?
To the employer and to the District Officer of the district (s.21(1)), the officer the State Government notifies under s.5. The Act prescribes no channel: SHe-Box lets a workplace's Nodal Officer submit it to the District Officer online, and some districts name their own channel, such as email from the organisation's official address in Gurugram.
When is the POSH annual report due?
The Act and Rules set no due date. Section 21 leaves the time to be prescribed, and Rule 14 prescribes none, so the date comes from your district: Gurugram, for example, set 28 February 2026 for calendar-2025 reports. Treat any other date you see as a planning target, not a statutory deadline.
What is the format of the annual report under the POSH Act?
The Rules prescribe the contents, not a form. Rule 14 requires five items: complaints received, complaints disposed of, cases pending over 90 days, workshops or awareness programmes held, and the nature of action taken. Use your district's or SHe-Box's format where one is asked for, as long as it carries those five.
Do we need to file a report if we had no complaints?
Yes. A nil return is required in years with no complaints; the reporting obligation under s.21 and Rule 14 is not conditional on there having been a complaint.
Is 31 January the legal deadline?
No. The Act and Rules prescribe no due date. District Officers set their own, and they vary; Gurugram, for example, set 28 February 2026 for calendar-2025 reports. The date for your district is confirmed, not assumed.
Who prepares the annual report, the Committee or HR?
The Internal Committee prepares it and submits it to the employer and the District Officer (s.21). HR usually supports with records; the employer separately includes the case numbers in its own annual report (s.22).
Can we file the annual report on SHe-Box?
Yes, if your workplace is registered. The portal lets the Nodal Officer submit the report to the District Officer digitally, and the Ministry expects annual reports to be updated there. Check whether your district also wants it by another channel.
We have multiple branches — how many reports do we file?
One per office or administrative unit, since each constitutes its own IC under s.4 and therefore has its own reporting obligation.
What happens if we miss the deadline?
The Act doesn't set a date, so it doesn't spell out a consequence for missing a district's date; treat the district's date as binding in practice. Failing to report at all is a contravention of s.21, which s.26(1) punishes with a fine of up to ₹50,000, with licence or registration consequences on a repeat conviction.
Does this service prepare the report or also submit it?
Both — report preparation and District Officer submission are included, along with nil returns.
Is Board's Report disclosure the same as District Officer filing?
No. Board's Report disclosure is a separate requirement under the Companies Act 2013 for applicable companies, distinct from the s.21 filing to the District Officer.
What if our IC's term expired before the reporting period closed?
The reporting obligation continues regardless; who signs for a Committee in transition is confirmed at scoping.
We just crossed the 10-employee threshold — when is our first report due?
Your first report covers the period since your IC was constituted; the exact start date is confirmed at engagement rather than assumed.
Can this service also constitute our IC?
Not within this engagement — Internal Committee formation is a separate service, and a validly constituted IC is a precondition for filing.
Where to go next
The three statutory clocks that start running, and where timelines slip.
What rule 8(5)(x) now requires for FY 2025-26, and the CS/CA checklist for AOC-4.
For CAs and Company Secretaries: the details to furnish, draft wording, and a free two-page PDF.
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 Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, section by section, on the Government of India's legislation repository.
The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, as notified on 9 December 2013.
An example of a district-set date: calendar-2025 annual reports due by 28 February 2026, by email from the organisation's official address.
The Ministry's statement that onboarding is mandatory for all workplaces including private entities, and how complaints are routed.
Sections 96 (AGM), 134 (Board's Report and the s.134(8) penalty) and 137 (filing with the Registrar).