Compliance
The POSH Act obliges every Internal Committee to file an annual report each year, even with no complaints, and failure can attract a fine of up to fifty thousand rupees, plus harsher penalties for repeat offences.
Check your DPDP readiness — free More on the blogSection 21 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 requires the Internal Committee – or the Local Committee where applicable – to prepare an annual report in a prescribed format every calendar year. The report must be submitted to two recipients: the employer and the District Officer. This dual submission is mandatory; sending the report only to the employer does not satisfy the legal requirement.
The prescribed contents are detailed. They include the number of complaints received during the year, the number of complaints that were disposed of, any cases that have remained pending for more than ninety days, the workshops and awareness programmes conducted, and the nature of the action taken in each case. Even if there were no complaints, the committee must still note a nil count and record any awareness activities undertaken.
Many small enterprises assume that a year without complaints means no report is needed. The law is clear that the report is annual, regardless of the complaint count. Another frequent error is stopping after handing the report to the employer, forgetting the statutory requirement to also send it to the District Officer. Omitting the awareness‑programme details is also a breach, as those activities form a mandatory part of the content.
Section 26 imposes a fine of up to fifty thousand rupees for failing to file the annual report. If the same breach occurs again, the penalty is doubled and can extend to cancellation of a licence or registration, effectively threatening the business’s ability to operate. The financial exposure therefore includes both the immediate fine and the potential loss of the right to trade. The penalty is not limited to the report alone. Section 26 also penalises failure to constitute an Internal Committee. Consequently, a business that has not set up the committee will almost certainly also lack the annual report, attracting the same fine. The two obligations are intertwined, and non‑compliance on one front triggers the same sanction. Because the District Officer forwards a brief summary of all received reports to the State Government, non‑filing becomes visible beyond the company’s walls. This external visibility can attract scrutiny from regulators and may affect the firm’s reputation, especially if the omission is repeated. To avoid the penalty, firms should maintain a simple checklist: prepare the report each year, include all prescribed items, and dispatch copies to both the employer and the District Officer before the deadline. Even a “nil” year should be documented, and awareness activities should be recorded throughout the year. Regular internal audits can verify that the report is ready on time and that the required copies reach the District Officer. Keeping a dated log of submission receipts provides evidence of compliance, which can be useful if the authorities request proof.
Yes. Section 21 obliges the Internal Committee to prepare an annual report every calendar year, even when no complaints are received. A year with zero complaints is reported as such, not omitted.
The report must be submitted to two parties: the employer and the District Officer. The District Officer then forwards a brief summary of all reports received to the State Government.
Section 26 provides a fine of up to fifty thousand rupees for failing to file the report. A repeat offence attracts double the fine and may lead to cancellation of a licence or registration.
Common errors include assuming no report is needed when there are no complaints, sending the report only to the employer, omitting awareness‑programme details, and not linking the reporting duty with the requirement to have an Internal Committee.
Published 4 October 2026. Founder & CEO at VidhiSar. I have watched four companies pay for the same mistake, and it was never the mistake anyone expected. VidhiSar is software, not a law firm: every answer names the section it relies on so you can check it, and anything turning on your specific facts is worth putting to a professional. More about who builds this
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