All NotificationsCorporate LawMinistry of Women and Child Development / MCA

Sexual Harassment of Women at Workplace Act, 2013 / Section 134(3)(q) Companies Act

POSH Act Corporate Governance: Mandatory Internal Complaints Committee (ICC) & Annual Director's Report Disclosures

Published: January 15, 20255 min readEffective: Mandatory Annual ComplianceDue: January 31 annually for District Officer Filing

View Official Gazette / Govt Source Consult Senior Partner

Executive Regulatory Summary

Every corporate employer with ten or more employees is statutorily mandated to constitute an Internal Complaints Committee (ICC) and comply with the POSH Act. Overview of committee composition, mandatory annual reporting to the District Officer by January 31st, mandatory disclosure in the Board's Report under Section 134, and severe business license cancellation risks.

Key Statutory Takeaways

Mandatory for every workplace, branch, or corporate office having ten or more employees.
Internal Committee must be headed by a senior woman employee, include 50% women members, and have 1 external independent NGO member.
Annual report must be filed with the local District Officer (Women & Child Welfare) by January 31st every calendar year.
The Director's Report in Form AOC-4 must include an explicit compliance statement detailing complaints received and resolved.

Actionable Compliance Checklist for Businesses

Step-by-step advisory measures prescribed by ASGR and CO for immediate adherence:

1Formally constitute Internal Committee by written executive order designating presiding officer and external member.

2Organize mandatory annual employee sensitization workshops and retain attendance rosters.

3Draft and submit the Annual POSH Report to the competent District Officer on or before January 31st.

4Ensure the statutory disclosure clause is accurately incorporated into the Board's Report annexed to Form AOC-4.

1. Corporate Penalties and Reputation Protection

Failure to constitute an Internal Committee incurs a direct fine of ₹50,000, and repeated violations empower state governments to cancel the company's shop and establishment license or incorporation certificate.

Target Entities Governed by this Notification:

Corporate Human Resources Heads & CHROsCompany Secretaries & Legal CounselsManaging Directors & Executive BoardsICC Committee Chairpersons

Advisory Published By

CA Sanjay Agarwal

Senior Partner & Co-Founder • B. Com, FCA, CS Inter, FAFD (ICAI)

ASGR and CO, Chartered Accountants (Peer Review Certified: #018Xxx)

Statutory Disclaimer: This publication is compiled by ASGR and CO solely for general informational and educational purposes to assist corporate clients and peers in understanding statutory notifications. It does not constitute legal, tax, or formal secretarial advice. Before acting upon any provisions, specific professional counsel should be sought.

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