Workforce · Provision

Section 21, POSH Act 2013 — The Annual Report Nobody Files

Section 21, Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013

The Internal Committee must prepare an annual report each calendar year and submit it to the employer and the District Officer.

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What the section does

  • The Internal Committee, or the Local Committee where that is the relevant body, must in each calendar year prepare an annual report in the prescribed form and at the prescribed time.
  • The report goes to two places: the employer, and the District Officer. Preparing it and handing it only to the employer does not discharge the section.
  • The District Officer forwards a brief report on the annual reports received to the State Government, which is how the obligation is visible from outside the business.
  • The prescribed contents cover the complaints received in the year, the complaints disposed of, the cases pending more than ninety days, the workshops and awareness programmes carried out, and the nature of the action taken.

On failure

up to ₹50,000. Section 26 penalises failure to file the annual report alongside failure to constitute an Internal Committee, and a repeat attracts twice the punishment and can reach a licence or registration.

The deadlines

  • Each calendar year — The Internal Committee prepares the annual report in the prescribed form.
  • On preparation — It is submitted to the employer and to the District Officer.
  • After receipt — The District Officer forwards a brief report to the State Government.

Where people go wrong

  • Filing nothing because there were no complaints. The report is annual and is due whether or not anybody complained — a nil year is still a year that has to be reported.
  • Submitting to the employer and stopping there. The section names the District Officer as well.
  • Leaving out the awareness programmes. They are part of the prescribed contents, and a report that covers only complaints is incomplete.
  • Treating it as separate from the Internal Committee obligation. Section 26 penalises both failures, which is why a business with no committee usually has no report either.

Common questions

Is the POSH annual report mandatory if there were no complaints?

Yes. Section 21 requires the Internal Committee to prepare an annual report in each calendar year and submit it to the employer and the District Officer. A year with no complaints is reported as such rather than skipped.

Who does the POSH annual report go to?

The employer and the District Officer. The District Officer then forwards a brief report on the annual reports received to the State Government.

What is the penalty for not filing the POSH annual report?

Section 26 provides a fine of up to ₹50,000 for contravention, which covers failure to file the annual report. A repeat contravention attracts twice the punishment and can extend to cancellation of a licence or registration.

Act on this

  • POSH annual report template
  • Section 4 — constituting the Internal Committee
  • Section 26 — what non-compliance costs

About this summary

A plain-English summary of what this provision requires, not a reproduction of it and not legal advice. Read alongside the bare Act, and take advice on anything turning on your own facts.