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The Prevention of Sexual Harassment (POSH) Act, 2013 applies to every organization in India with 10 or more employees — including startups and small businesses that may not think of themselves as large enough to need formal HR compliance. Non-compliance carries financial penalties and reputational risk.

What the law requires

  • A written POSH policy, communicated to all employees
  • A constituted Internal Committee (IC), including an external member
  • A defined, confidential complaint and investigation process
  • Annual POSH awareness training for employees
  • An annual return filed with the local District Officer

Common gaps we see

No external member on the Internal Committee

This is a legal requirement, not optional — and one of the most frequently missed elements of an otherwise-compliant POSH setup.

Policy exists but was never actually communicated

A policy buried in an onboarding folder that nobody has read doesn't meet the spirit or, in practice, the intent of the requirement.

No training has ever been conducted

Awareness training is a specific requirement, not implied by having a policy document.

No process for handling a complaint if one is raised

Many committees exist on paper but have never been briefed on the confidential process and timelines the law requires for handling a complaint.

Getting compliant

  1. Draft or review your POSH policy against current requirements
  2. Constitute an Internal Committee with the required external member
  3. Communicate the policy and committee details to all employees
  4. Conduct awareness training
  5. File your annual return
POSH compliance isn't just a legal checkbox — a properly implemented policy and committee also give employees genuine confidence that concerns will be taken seriously.

This is one of the add-on services we frequently implement for growing businesses that have scaled past 10 employees without formalizing this requirement.

Need this handled for your business?

Our HR team can implement everything in this article as part of a structured engagement.

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