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What It Covers

PoSH Compliance, Done Right.

Skipping it risks heavy penalties, licence cancellation for repeat offences, and lawsuits. We frame the policy, set up the Internal Committee, provide the external member (a legal advocate), train your committee, run sensitization for staff, and file your annual return with the District Officer.

“The PoSH Act applies to every Indian workplace with 10 or more employees.”

What TMS Offers

End-to-End PoSH Compliance.

PoSH policy framing

Custom-drafted PoSH policy aligned to your industry, state and headcount, ready for board sign-off and circulation to all employees.

Internal Committee setup

We constitute the 4-member Internal Committee, including a TMS-provided external member (a legal advocate), the mandatory external seat.

Committee training

PoSH sensitization for IC members: what to do when a complaint arrives, how to investigate, how to document, how to close out.

Employee sensitization

Awareness training for all staff: what counts as harassment, how to report, retaliation protection, confidentiality, and the role of the IC.

Annual return filing

Section 21 and Rule 14 require an annual report to the District Officer. We compile and file it on your behalf each year.

Complaint handling

When a complaint comes in, we run the inquiry as your external IC member: interviews, evidence, written findings and recommended action. A per-case charge applies.

Internal Committee

IC Setup and External IC Member.

The PoSH Act 2013 requires every workplace with 10 or more employees to constitute an Internal Committee with at least one external member from an NGO or social-work background. TMS provides both the IC setup and qualified external members for organisations across India.

  • IC composition: a Presiding Officer who is a senior woman employee, 2 internal members, and 1 external member from an NGO or legal background.
  • External IC member: TMS senior consultants serve as external members, on retainer or on a per-inquiry basis.
  • Inquiry procedure: confidential inquiry within 90 days, decided on the balance of probabilities, with written findings and reasons.
  • Documentation: complaint register, meeting minutes, inquiry reports, and the annual District Officer filing.
The PoSH Act

What the PoSH Act Requires from Indian Employers.

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013, commonly called the PoSH Act, applies to every workplace in India that employs 10 or more workers. Compliance is not optional, and it is independently verifiable through the annual report filed with the District Officer.

Six mandatory deliverables under the PoSH Act

  • A written PoSH policy circulated to all employees, in English and the regional language of the workplace, signed off by the principal employer.
  • An Internal Committee with a Presiding Officer who is a senior woman employee, at least two internal members committed to women’s issues or with a legal background, and an external member from an NGO or expert in sexual harassment.
  • Awareness training for all employees including contract staff, with a refresher every 12 months and dedicated training for IC members.
  • A complaint-handling SOP: receipt, an option for conciliation, inquiry within 90 days, a written report with findings and recommendations, and action within 60 days of the report.
  • An annual report to the District Officer by 31 January each year, with the number of complaints received, disposed and pending, and the workshops conducted.
  • Display of the penal consequences of sexual harassment and the IC composition prominently at all workplaces.
Training

In-Person, E-Learning and IC Capacity Building.

The PoSH Act mandates regular employee training plus separate IC capacity building. TMS delivers training in three formats: live in-person sessions at your office, asynchronous e-learning with completion tracking, and intensive IC member workshops.

All-employee

In-person workshops or e-learning modules, bilingual content in English and regional languages, with completion certificates.

Manager

Scenario-based modules on identifying, reporting and responding to complaints.

IC member

A 2-day intensive on inquiry procedure, evidence standards and report writing.

Refresher

Annual refresher sessions, mandatory under Section 19 of the PoSH Act.

Annual Audit

PoSH Audit and District Officer Report.

Every employer must file an annual report with the District Officer. A TMS PoSH audit checks your policy, committee and records against the Act and prepares the filing.

Gap report

A structured gap report with a remediation plan and a District Officer filing draft.

Turnaround

Typically 7 to 10 working days from receipt of your data.

Penalty avoidance

Non-compliance attracts fines up to Rs 50,000 for a first offence, doubled for repeat offences, plus licence cancellation.

Penalties for non-compliance: a first-time fine up to Rs 50,000; a repeat offence can attract twice the fine, cancellation of the business licence, or de-registration. Beyond the fine, the bigger risks are reputational damage, mandatory disclosure in IPO documents, and class-action exposure under the Companies Act 2013 director-duty provisions.

Why TMS

One Team for Policy, Committee and Filing.

Since 2006

A compliance-first HR firm that has run Indian statutory and HR work for close to two decades.

External members on tap

Qualified external IC members sourced from our empanelled NGO and legal network.

Bilingual and pan-India

Policy and training in English and regional languages, delivered across the country.

How TMS delivers PoSH compliance

TMS bundles policy drafting in English and the regional language, IC nomination support with external-member sourcing from our empanelled NGO network, annual training in classroom or e-learning format, complaint-handling advisory through the inquiry life-cycle, and annual report preparation. Engagements run as an annual retainer or per incident, depending on company size and risk profile. Contact: [email protected], +91 22 4896 7640.

Need PoSH set up or your annual return filed?

Tell us your headcount and locations, and get a scoped PoSH plan.

Related Services

Other Ways TMS Can Help.

Statutory Compliance

PF, ESIC, PT and more across all 28 states.

Learn more ›

HR Consulting

Policy, handbooks and senior HR advisory.

Learn more ›

Payroll Outsourcing

Payroll and statutory delivery at scale.

Learn more ›

Talent Acquisition

Hiring strategy and delivery across India.

Learn more ›

Frequently Asked Questions

PoSH FAQs.

Is PoSH compliance mandatory?

Yes. Any workplace in India with 10 or more employees must comply with the PoSH Act 2013: policy, an Internal Committee, training, and the annual return are all required.

Can TMS provide the external IC member?

Yes. TMS provides a qualified external member, a legal advocate, as the mandatory external seat on the Internal Committee, included in the annual fee.

What if a complaint comes in?

We can run the inquiry as your external IC member: interviews, evidence, written findings, and recommended action. This is charged per case, separate from the annual retainer.

What POSH Act compliance requires from Indian employers

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013, commonly called the POSH Act, applies to every workplace in India that employs 10 or more workers. Compliance is not optional and is independently verifiable through the annual report filing requirement at the District Officer level.

Six mandatory deliverables under the POSH Act

  1. Written POSH policy circulated to all employees, in English and the regional language of the workplace, signed off by the principal employer
  2. Internal Committee (IC) constitution with a Presiding Officer who is a senior woman employee, at least two internal members committed to women issues or with legal background, and an external member from an NGO or expert in sexual harassment
  3. Awareness training for all employees including contract staff, with refresher every 12 months and dedicated training for IC members
  4. Complaint handling SOP: receipt, conciliation option, inquiry within 90 days, written report with findings and recommendations, action within 60 days of report
  5. Annual report to District Officer by 31 January each year, with number of complaints received, disposed, pending, and workshops conducted
  6. Display of consequences: penal consequences of sexual harassment and the IC composition prominently displayed at all workplaces

Penalties for non-compliance

First-time non-compliance attracts a fine up to Rs 50,000. Repeat offence may attract twice the fine, cancellation of business licence or de-registration. Beyond the statutory fine, the bigger risks are reputational damage in employer brand surveys, mandatory disclosure in IPO documents, and class-action exposure under the Companies Act 2013 director-duty provisions.

How TMS delivers POSH compliance

TMS bundles policy drafting in English and the regional language, IC nomination support with external-member sourcing from our empanelled NGO network, annual training in classroom or e-learning format, complaint-handling advisory through the inquiry life-cycle, and annual report preparation. Engagements are annual retainer or per-incident, depending on company size and risk profile.

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