1. Introduction

2. What is the POSH Annual Report?

3. Key deadlines employers must track 

4. What the POSH Annual Report must contain?

5. Reporting for organisations with multiple locations

6. If an organisation has multiple branches in the same district, is a separate POSH Annual Report required?

7. Consequences of non-compliance

8. Who is required to submit the Annual Report?

9. POSH Compliance Checklist for Employers 

10. Filing on SHe-Box

1. Introduction

As the calendar year comes to an end, employers are required to complete annual compliance under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, commonly known as the POSH Act. For organisations with ten or more employees, a key statutory requirement is filing the POSH Annual Report, with the deadline falling in January 2026.

At this time, the Gurugram District Administration has issued a notification directing organisations within its jurisdiction to submit a POSH compliance checklist along with the supporting documents, in addition to the Annual Report. The checklist requires employers to confirm proper constitution of the Internal Committee, display of POSH notices, compliance with POSH procedures during inquiries, and timely filing of the Annual Report.

While the notification applies to Gurugram, its relevance extends across India. Following the Supreme Court’s direction to conduct district wise survey in Aureliano Fernandes v State of Goa, District Officers are actively verifying POSH compliance. This means that filing the Annual Report alone may not be sufficient, and employers may be required to demonstrate compliance through records and supporting documents.

This notification serves as a reminder that POSH compliance is not a tick box exercise, but a continuous legal obligation.

This blog explains what POSH Annual Report is, what the Gurugram notification entails, who must file the report, what it must contain, applicable timelines, consequences of non-compliance, and how these developments change the compliance expectations for employers.

2. What is the POSH Annual Report? 

Under the POSH Act, every organisation with ten or more employees is required to constitute an Internal Committee. One of the statutory responsibilities of the Internal Committee under section 21 of the POSH Act is to prepare an Annual Report summarising complaints received, and preventive measures taken during the calendar year.

There are two separate annual reporting obligations under the POSH framework.

a. Internal Committee Annual Report

This report is prepared by the Internal Committee and submitted to:

• The employer for internal records
• The District Officer having jurisdiction over the workplace

It contains complaint data, status of inquiries, awareness initiatives, and action taken by the employer.

b. Board’s Report Disclosure

Similarly, Section 22 of the POSH Act requires the employer to include very specific details about the organization’s POSH compliance efforts in the report, which is then shared with the District Officer.

In addition to the Internal Committee Annual Report, companies are also required to make a POSH compliance disclosure in their Board’s Report under the Companies Act, 2013.

The Board’s Report is the company’s official annual report placed before shareholders. Through this disclosure, the Board of Directors formally confirms that:

• An Internal Committee has been duly constituted under the POSH Act
• The company has complied with POSH requirements during the year
• Details of complaints received and disposed of have been appropriately addressed

This disclosure does not include detailed case facts or identities. It is a declaration of compliance and accountability at the board level.

Any incorrect, incomplete, or missing POSH disclosure in the Board’s Report can attract penalties for the company and its directors.

3. What is the deadline for filing Annual report?

POSH reporting follows the calendar year from 1st  January to 31st  December, not the financial year.

4. What the POSH Annual Report must contain? 

As per Rule 14 of the POSH Rules, the Internal Committee Annual Report must include:

• Number of complaints received during the year
• Number of complaints disposed of
• Number of cases pending for more than ninety days
• Action taken by the employer based on IC recommendations
• Number of awareness programs and IC orientation sessions conducted
• Nature of action taken, without disclosing identities

Even where no complaints were received, a Nil Annual Report must still be filed.

5. Reporting for organisations with multiple locations 

Where an organisation operates across multiple districts:

• Separate Annual Report must be filed with each District Officer.
• Head office filing does not replace district wise reporting.

For example, an organisation with offices in Gurugram, Bengaluru, and Mumbai with more than 10 or more employees in each of the offices, must file three separate reports.

6. If an organisation has multiple branches in the same district, is a separate POSH Annual Report required?

If an organisation has multiple branch offices within the same district, it is important to maintain branch wise POSH records for each workplace. Organisations may choose to file a single consolidated POSH Annual Report covering all such branches or separate Annual Reports for each branch, depending on internal administrative convenience.

However, the Annual Report must clearly capture and disclose POSH compliance details for each branch office, and no workplace can be excluded from reporting.

7. Consequences of non-compliance

As per section 26 of the POSH Act, failure to file the POSH Annual Report or incorrect reporting can lead to:

• Penalty up to fifty thousand rupees for first time default
• Double penalties for repeated violations
• Cancellation or non-renewal of licences

Incorrect POSH disclosures in the Board’s Report can also attract penalties under company law.

8. Who is required to submit the Annual Report? 

The obligation applies to all workplaces with ten or more employees, including:

• Private companies and startups
• Public sector undertakings
• Factories and manufacturing units
• Educational institutions
• Hospitals and healthcare establishments
• NGOs and trusts

9. POSH Compliance Checklist for Employers 

The Gurugram District Administration has directed employers within its jurisdiction to submit the POSH Annual Report along with a compliance checklist and supporting documents. The compliance checklist requires employers to provide details and proof of the following:

a. Internal Committee constitution

Details of the Presiding Officer, Internal Members, and External Member, along with document proving Committee constitution (such as board resolution extract), confirming that the IC is formed as per the POSH Act.

b. Display of POSH notices at the workplace

Confirmation of where POSH notices stating that instances of sexual harassment are not tolerated and its consequences are displayed, such as entrance areas, notice boards, HR desks, or common areas, along with a sample copy or photograph of the notice.

c. POSH Annual Report filing

Confirmation that the Annual Report has been prepared and submitted within the prescribed timeline, along with proof of submission to the District Officer.

d. Training and awareness programs

Details of POSH awareness sessions and IC orientation programs conducted during the year, including dates, mode of training, and attendance records.

e. Records and documentation readiness

Confirmation that complaint records, inquiry documents, and action taken reports are maintained and available for verification, where required.

10. Filing on SHe-Box

As of now, there is no clear guidance on submitting the POSH Annual Report directly through the SHe-Box portal. The portal currently only seeks confirmation on whether the Annual Report has been submitted.

In view of this, eLearnPOSH suggests that employers continue to submit the POSH Annual Report through the prescribed physical or email mode to the District Officer and use She Box only to indicate the status of such submission, until further clarity is issued by the authorities.

Need help drafting the POSH Annual Report?

If you need support with preparing or filing the POSH Annual Report, eLearnPOSH can help.

eLearnPOSH has developed a comprehensive microlearning course on POSH Annual Reporting and filing with the District Officer. The course covers everything employers and Internal Committee members need to know, starting from preparation of the Annual Report to the correct filing process.

Along with the course, you also receive free Annual Report and Director’s Report templates, which can be directly used for compliance purposes.

To access this POSH Annual Reporting course at an attractive price, you can reach out to the eLearnPOSH team.