PoSH Compliance Services in India — IC Setup, Audits & Training.
PoSH Act 2013 compliance for Indian workplaces — policy, Internal Complaints Committee setup, training and annual return filing, delivered by senior HR professionals.
PoSH compliance, done right.
Skipping it risks heavy penalties, business closure, and lawsuits. We frame the policy, set up the Internal Complaints Committee, provide the external 4th member (a legal advocate), train your ICC, run sensitization for staff, and file your annual compliance return with the District Officer.
“The PoSH Act applies to every Indian workplace with 10+ employees.”
What TMS offers in PoSH
PoSH Policy framing
Custom-drafted PoSH policy aligned to your industry, state and headcount — ready for board sign-off and circular distribution to all employees.
ICC setup (4 members)
We set up the 4-member Internal Complaints Committee, including a TMS-provided external legal advocate as the mandatory 4th member.
ICC training
PoSH case sensitization training for ICC members — what to do when a complaint arrives, how to investigate, how to document, how to close out.
Employee sensitization
Awareness training for all employees — what counts as harassment, how to report, retaliation protection, confidentiality, and the role of the ICC.
Annual return filing
Section 21 + Rule 14 of the PoSH Act require an annual report to the District Officer. We compile and file it on your behalf, on time, every year.
PoSH complaint handling
When a complaint comes in, we run the inquiry as the ICC chair / external member — interviews, evidence, written findings and recommended action. (Additional charges per case.)
Internal Committee (IC) Setup & External IC Member
The POSH Act 2013 requires every workplace with 10+ employees to constitute an Internal Committee with at least one external member from an NGO or social work background. TMS provides both IC setup and certified external IC members for organisations across India.
IC Composition: Presiding Officer (senior woman), 2 internal members, 1 external member from NGO/legal background
External IC Member: TMS senior consultants serve as external members on retainer or per-inquiry basis
Inquiry Procedure: Confidential inquiry within 90 days, balance of probabilities standard, written findings with reasons
Documentation: Complaint register, meeting minutes, inquiry reports, annual District Officer filing
PoSH Annual Audit & District Officer Report
Every employer must file an Annual Report with the District Officer by 31 January each year, summarising complaints received, action taken, and training coverage. TMS conducts an annual PoSH audit before filing — verifying IC composition, policy adherence, training coverage, complaint register integrity, and statutory signage.
Scope: IC composition, written policy, training records, complaint register, signage, annual report
Output: Risk-scored gap report with remediation plan and District Officer filing draft
Timeline: 7–10 working days from data receipt
Penalty avoidance: Non-compliance penalties up to Rs 50,000 for first offence, doubled for repeat offences plus licence cancellation
PoSH 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 training: In-person workshops or e-learning modules, bilingual content (English + regional languages), completion certificates
Manager training: Scenario-based modules on identifying, reporting, and responding to complaints
IC member training: 2-day intensive on inquiry procedure, evidence standards, report writing
Refresher: Annual refresher sessions — mandatory under Section 19 of POSH Act
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
Written POSH policy circulated to all employees, in English and the regional language of the workplace, signed off by the principal employer
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
Awareness training for all employees including contract staff, with refresher every 12 months and dedicated training for IC members
Complaint handling SOP: receipt, conciliation option, inquiry within 90 days, written report with findings and recommendations, action within 60 days of report
Annual report to District Officer by 31 January each year, with number of complaints received, disposed, pending, and workshops conducted
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.
How a PoSH engagement runs
Brief
30-minute call to understand your headcount, locations, and current state of PoSH compliance.
Proposal
Scope: policy + ICC + training + annual return. Fixed annual fee, no hidden costs. Within 48 hours.
Engagement
We set up policy, ICC, run training, and start the annual filing cycle. SPOC throughout.
Annual renewal
Annual compliance return filed; ICC refresher training; renew for next year.
Book a 30-min PoSH compliance call.
Free intro call to scope the situation. If we can help, we’ll send a proposal within 48 hours.
Frequently Asked Questions
Is PoSH compliance mandatory?
Yes. Any workplace in India with 10 or more employees must comply with the PoSH Act 2013 — policy, ICC, training, and annual return are all required.
Can TMS provide the external ICC member?
Yes. TMS provides a qualified external legal advocate as the mandatory 4th ICC member, included in the annual fee.
What if a complaint comes in?
We can run the inquiry on your behalf as ICC chair/external member — interviews, evidence, written findings, recommended action. Per-case fee, separate from annual retainer.
Talk to our sales team.
Tell us what you need.
Sales (IVR): +91 22 4896 7640
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