Section 19 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Section 19 is the employer's checklist in the Act. It has ten clauses, (a) to (j), covering a safe working environment, notice display, awareness programmes, support to the committee, help to a woman who wishes to file a police complaint, treating sexual harassment as misconduct, and monitoring committee reports. If you manage a workplace, our labour law compliance service can help you turn the ten clauses into a working routine.
Every employer shall: (a) provide a safe working environment; (b) display the penal consequences of sexual harassment and the order constituting the Internal Committee; (c) organise workshops and awareness programmes and orientation for committee members; (d) provide facilities to the committee; (e) assist in securing attendance of respondent and witnesses; (f) make available information; (g) assist the woman who files a complaint under the Indian Penal Code or other law; (h) cause to initiate action under that Code or other law; (i) treat sexual harassment as misconduct under the service rules; and (j) monitor timely submission of reports by the Internal Committee.
Source and names
We follow the consolidated text of the Act consulted (it shows one amendment, Act 23 of 2016, with effect from 6 May 2016); later amendments and notifications should be checked. The 2016 change of name of the committees is shown in the footnotes. The Rules are cited from the copy consulted (the Rules as notified on 9 December 2013). Section 19 names the Indian Penal Code (45 of 1860) in clauses (g) and (h), quoted as printed; check the current penal law for the corresponding provision. The four Labour Codes are in force from 21 November 2025; check the current position before relying on any other labour law.
The ten duties
The section begins "Every employer shall", and each clause is a duty. Section 2(g) defines who the employer is; see our article on section 2.
| Clause | Duty |
|---|---|
| (a) | Provide a safe working environment at the workplace which shall include safety from the persons coming into contact at the workplace |
| (b) | Display at any conspicuous place in the workplace the penal consequences of sexual harassment, and the order constituting the Internal Committee under section 4(1) |
| (c) | Organise workshops and awareness programmes at regular intervals for sensitising the employees with the provisions of the Act, and orientation programmes for the members of the Internal Committee, in the manner as may be prescribed |
| (d) | Provide necessary facilities to the Internal Committee or the Local Committee for dealing with the complaint and conducting an inquiry |
| (e) | Assist in securing the attendance of respondent and witnesses before the committee |
| (f) | Make available such information to the committee as it may require, having regard to the complaint made under section 9(1) |
| (g) | Provide assistance to the woman if she so chooses to file a complaint in relation to the offence under the Indian Penal Code or any other law |
| (h) | Cause to initiate action under the Indian Penal Code or any other law against the perpetrator, or if the aggrieved woman so desires, where the perpetrator is not an employee, in the workplace at which the incident took place |
| (i) | Treat sexual harassment as a misconduct under the service rules and initiate action for such misconduct |
| (j) | Monitor the timely submission of reports by the Internal Committee |
Clause (a): safe working environment
The copy prints "with shall include" for "which shall include"; a printing slip. The duty reaches "safety from the persons coming into contact at the workplace", so it is not limited to co-workers. The text does not list measures. For the meaning of workplace see part two of section 2.
Clause (b): display
The copy prints "sexual harassments; and the order constituting, the Internal Committee"; printing slips in punctuation and plural. Two things go on display at a conspicuous place: the penal consequences of sexual harassment and the order that constituted the Internal Committee under section 4(1), which must be an order in writing (see section 4). The text does not say what form the display takes or what the "penal consequences" notice must contain beyond those words.
Clause (c): workshops and awareness programmes
Clause (c) says "in the manner as may be prescribed", and Rule 13 fills this; see our article on Rule 13. The Act says "at regular intervals" and does not fix the interval. See also our guide on POSH awareness training.
Clauses (d), (e) and (f): support to the committee
These three are about practical help. Facilities (a room, staff, records) for dealing with the complaint and conducting the inquiry; assistance in securing the attendance of respondent and witnesses; and information that the committee requires, having regard to the complaint under section 9(1). The copy prints "as the case be" in clause (f); a printing slip. The text does not say how the employer is to secure attendance beyond "assist".
Clauses (g) and (h): criminal law routes
Clause (g) is about assistance to the woman "if she so chooses" to file a complaint in relation to the offence under the Indian Penal Code (45 of 1860) or any other law. Clause (h) is harder to read as printed: the employer shall "cause to initiate action, under the Indian Penal Code (45 of 1860) or any other law for the time being in force, against the perpetrator, or if the aggrieved woman so desires, where the perpetrator is not an employee, in the workplace at which the incident of sexual harassment took place". We quote it and do not rewrite it into a firmer rule. The words "if she so chooses" in clause (g) and "if the aggrieved woman so desires" in clause (h) point to the woman's wishes.
Clause (i): misconduct
The employer shall "treat sexual harassment as a misconduct under the service rules and initiate action for such misconduct". This links to section 13(3)(i). Where there are no service rules, Rule 9 prescribes the manner; see Rule 9.
Clause (j): monitoring reports
The employer shall monitor "the timely submission of reports by the Internal Committee". The reports are the annual reports under section 21; see our article on section 21. For the District Officer's matching duty for the Local Committee, see sections 5 and 20.
What happens if the employer does not comply
Section 26 punishes an employer who fails to constitute the Internal Committee, fails to take action under sections 13, 14 and 22, or contravenes other provisions of the Act or the Rules, with a fine which may extend to fifty thousand rupees. Section 19 duties fall within "other provisions". See our article on section 26.
An example
Greenfield Foods has two plants and a head office. The HR head prepares a ten-line register, one line per clause of section 19. For clause (b), copies of the written order constituting each Internal Committee are displayed at each location. For clause (c), a calendar of sessions is kept. For clause (j), a note records the date on which each Internal Committee's report is due. When an employee, Alka, tells the Presiding Officer that she wishes to file a police complaint, the HR head records the request and offers assistance, in line with clause (g).
Need help with employer compliance?
A register of the ten duties, with an owner and a date for each, is the simplest way to keep track. Our labour law compliance team can set it up with you, and our guides on a POSH policy draft and a POSH compliance checklist give a general starting point.
Key takeaways
- Section 19 lists ten duties (a) to (j); each begins with "shall".
- Display the penal consequences and the order constituting the Internal Committee at a conspicuous place.
- Workshops and awareness programmes at regular intervals; Rule 13 fills the manner.
- Support the committee with facilities, attendance and information.
- Treat sexual harassment as misconduct and monitor the Internal Committee's reports.
Read next
- Section 21 of the POSH Act, 2013: annual report
- Section 26 of the POSH Act, 2013: penalty for non-compliance by employer
- Rule 13 of the POSH Rules, 2013: workshops, awareness programmes and internal policy
- POSH Compliance for Small Companies and Startups
Disclaimer: Based on a consolidated text of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 showing one amendment (Act 23 of 2016, 6 May 2016) and on a copy of the Rules of 2013 as notified on 9 December 2013, as consulted on 2 October 2026. Later amendments, State rules and notifications, and the position under the Labour Codes in force from 21 November 2025 should be checked. This article is general information, not legal advice; check the official text before acting.