Workforce · Provision

Section 21, POSH Act 2013 — The Mandatory POSH Annual Report

The Internal Committee must prepare an annual report in each calendar year and submit it to the employer and District Officer, even if zero complaints were received. (Section 21, Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.)

Quick Statutory Answer

Under Section 21 of the POSH Act 2013, the Internal Committee must prepare and submit an Annual Report in each calendar year to the employer and to the District Officer. Under Rule 14 of the POSH Rules, the report must specify the number of sexual harassment complaints received, complaints disposed of, cases pending over 90 days, workshops and awareness programs conducted, and nature of actions taken. Even if zero complaints were received during the year, filing a NIL annual report remains legally mandatory under Section 21.

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What the section does

  • The Internal Committee (IC) must in each calendar year prepare an Annual Report in the prescribed form and submit it to the employer and to the District Officer.
  • The report must set out: (a) number of complaints of sexual harassment received in the year; (b) number of complaints disposed of; (c) number of cases pending for more than ninety days; (d) number of workshops or awareness programmes carried out; and (e) nature of action taken by the employer.
  • The employer must also include this information in the Director’s Report / Board’s Report under Section 134 of the Companies Act 2013.
  • Filing a NIL report is mandatory where no complaints were filed; omitting the report because no complaints arose does not satisfy Section 21 and triggers Section 26 penalties.

Section 21 POSH Act: Annual Report Mandatory Disclosures & Filing Rules (2026)

Section 21 POSH Act: Annual Report Mandatory Disclosures & Filing Rules (2026)
Required Disclosure Item Statutory Rule Reference Mandatory Minimum Standard Legal Consequence If Omitted
Number of Complaints Received POSH Rules Rule 14(a) Exact count received during calendar year Incomplete statutory filing
Number of Complaints Disposed of POSH Rules Rule 14(b) Disposal within 90-day inquiry window Scrutiny on delayed inquiries
Cases Pending More Than 90 Days POSH Rules Rule 14(c) Explanation for statutory inquiry delay Regulatory inquiry from District Officer
Awareness Programmes & Workshops POSH Rules Rule 14(d) Dates & attendance of staff POSH workshops Proof of Section 19 employer duties
Action Taken by Employer POSH Rules Rule 14(e) Implementation of IC inquiry recommendations Employer liability under Section 26
NIL Annual Report Confirmation Rule 14 & Section 21 Explicit filing confirming 0 complaints Treated as unfiled report (₹50k fine)

On failure to file

Up to ₹50,000 fine. Penalised under Section 26; repeat default attracts double fine and licence cancellation risk.

The deadlines

  • Each calendar year (by 31 January) — The Internal Committee prepares the annual report in the prescribed form.
  • Immediately on preparation — Submitted to the employer and to the designated District Officer.
  • Board Report compilation — Disclosed in the annual Director's Report under Companies Act Section 134.

Where people go wrong

  • Submitting the report only to internal management. The statute mandates delivery to the District Officer.
  • Omitting the report because there were no complaints. A NIL report is legally required.
  • Failing to document staff training sessions. Workshops are a mandatory statutory reporting item.
  • Missing the annual corporate governance disclosure in the MCA Director's Report.

Common questions

Who must the POSH annual report be submitted to?

Under Section 21, the report must be submitted to both the employer and the designated District Officer (often the District Magistrate, Collector, or Deputy Collector) in each calendar year.

Is a POSH annual report required if no complaints were filed?

Yes. Filing a NIL report is mandatory. The law requires recording that zero complaints were received, along with disclosures of employee awareness programmes conducted during the year.

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

Under Section 26 of the POSH Act, failure to submit the annual report is punishable with a fine of up to ₹50,000, and repeat violations can lead to cancellation of business licences.

Act on this

  • POSH annual report format (Word)
  • POSH policy template
  • Section 4 — Internal Committee rules
  • Section 26 — non-compliance penalties

Other provisions

  • Section 4, Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act
  • Section 19, Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act
  • Section 26, Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act
  • Section 13, Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act
  • Section 9, Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act
  • Section 11, Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act

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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.