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POSH Act: Prevention of Sexual Harassment at Workplace — Compliance and Inquiry

The Prevention of Sexual Harassment (POSH) Act 2013 mandates all workplaces with 10 or more employees to constitute an Internal Complaints Committee. Learn about ICC constitution, ...

TaxClue Team Tax & Compliance Expert
2 min read 15 views Updated Jun 16, 2026
Expert Reviewed High Complexity
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The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013 (POSH Act) makes it mandatory for organizations to prevent and address sexual harassment at the workplace. It was enacted following the Vishaka v. State of Rajasthan (1997) Supreme Court guidelines.

Definition of Sexual Harassment

Sexual harassment includes unwelcome acts or behaviour (direct or implied) such as:

  • Physical contact and advances
  • Demand or request for sexual favours
  • Making sexually coloured remarks
  • Showing pornography
  • Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature

These behaviors also include: implied or explicit promise of preferential treatment, threat, intimidation, creation of hostile work environment, or humiliating treatment affecting dignity.

Applicability

  • All employers with 10 or more employees (not just permanent employees)
  • Protects women employees including temporary, ad-hoc, domestic workers, contract workers
  • Covers both physical and virtual/online workplace environments
  • Extended to unorganized sector through Local Complaints Committee (LCC)

Internal Complaints Committee (ICC)

Every employer with 10 or more employees must constitute an ICC:

MemberRequirement
Presiding OfficerSenior woman employee; if not available, nominated from another office/unit
Employee MembersMinimum 2 members from employees (preferably committed to women's issues)
External MemberFrom NGO/association committed to women's issues or person familiar with such issues
CompositionMinimum 50% members must be women
Tenure3 years (for all members)

Inquiry Process

  1. Complaint filing: Written complaint within 3 months of incident (extendable by 3 months for exceptional reasons)
  2. Acknowledgment: ICC must acknowledge within 7 days
  3. Conciliation: If requested by complainant, ICC can attempt conciliation (no monetary settlement in conciliation)
  4. Inquiry: If conciliation fails or not requested, formal inquiry initiated; respondent given copy of complaint
  5. Completion: Inquiry must be completed within 60 days
  6. Report: ICC submits inquiry report with recommendations to employer within 10 days of inquiry completion
  7. Employer Action: Employer must act on ICC recommendations within 60 days

Interim Relief

During pending inquiry, the complainant can request interim measures:

  • Transfer of complainant or respondent to a different department/unit
  • Grant of leave to complainant up to 3 months (paid)
  • Restraint on respondent from reporting on complainant's work

Employer Obligations (Section 19)

  • Display notice of POSH provisions at workplace
  • Organize awareness programs and sensitization workshops
  • Provide safe working environment
  • Treat ICC proceedings as confidential
  • Include POSH compliance in Annual Report
  • File annual report to District Officer (Form D)

Annual Report to District Officer

Every employer must file an annual report with the District Officer (under Department of Labour) containing:

  • Number of complaints received
  • Number of complaints disposed of
  • Number of cases pending as on year end
  • Details of workshops, awareness programs conducted

Need Help with Compliance?

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Frequently Asked Questions
Is POSH applicable to companies with fewer than 10 employees?
Employers with fewer than 10 employees are not required to constitute an ICC. However, complaints against such employers can be filed with the Local Complaints Committee (LCC) set up by District Officers. The POSH Act protections apply to all women workers regardless of employer size.
Can a man file a complaint under POSH Act?
The POSH Act 2013 specifically protects women against sexual harassment. A man cannot file a complaint under POSH. However, men may have remedies under IPC (Section 354A) or through internal company HR policies. Some companies have extended their internal POSH-like policies to cover all genders.
What is the timeline for ICC to complete inquiry?
The ICC must complete its inquiry within 60 days from the date of initiation of the inquiry. After inquiry completion, the ICC must submit its report with recommendations to the employer within 10 days. The employer must act on the recommendations within 60 days.
Who should be the external member of ICC?
The external member should be from an NGO or association committed to the cause of women, or a person familiar with issues relating to sexual harassment. The external member provides independence and helps prevent internal bias. NGO partner directories are maintained by many state governments.
What happens after ICC submits its recommendation?
Based on ICC recommendations, the employer must take action within 60 days. Actions include: warning, written apology, withholding promotion/increment, termination, or requiring payment of compensation to the complainant. Non-implementation of recommendations exposes the employer to POSH penalties.
Is POSH training mandatory for employees?
Yes, Section 19 requires employers to organize POSH awareness programs and workshops for employees including sensitization on what constitutes sexual harassment, ICC procedures, and consequences. Though no specific frequency is prescribed, most companies conduct annual POSH training and include it in new employee induction.

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