Workforce compliance (POSH Act, 2013) · Template

POSH annual report format — the s. 21 filing to the District Officer

Most companies that constitute an Internal Committee stop there. The Act does not. The Committee owes a report every calendar year, to the employer and to the District Officer, and it is owed whether or not a single complaint was ever made. A nil year still has a filing.

Quick Statutory Answer

Do I have to file a POSH annual report if there were no complaints? Yes. The obligation under s. 21 is annual and does not depend on a complaint having been made. A nil report is filed exactly like any other, and the awareness-programme particulars are due whether or not anyone complained.

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POSH Annual Report format

The full text of this document as VidhiSar drafts it, with every blank shown in square brackets. Copy it or download it as a Word file and fill it in yourself — or answer a few questions and VidhiSar fills it in and prints a formatted PDF. Clauses that apply only in some cases are left out here; the drafting flow adds them when your answers call for them.

REPORT DETAILS

Date: [Date of This Report]

Annual Report of the Internal Committee for the calendar year [Reporting Calendar Year]

Submitted by: [Company Legal Name], having its registered office at [Registered Business Address] Submitted to: The District Officer, [District Officer / District of the Workplace], and to the Employer

This Report is prepared and submitted under Section 21 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, read with the rules framed thereunder.

INTERNAL COMMITTEE

1. Constitution. The Internal Committee of [Company Legal Name] is constituted under Section 4 of the Act and is presided over by [Internal Committee Presiding Officer]. Its composition, including the member drawn from a non-governmental organisation or association familiar with issues relating to sexual harassment, is as recorded in the Company's Internal Committee Constitution Order.

2. Employee Strength. The total employee strength of the Company as at the close of the reporting year was [Total Employee Strength at Year End], counted so as to include interns, probationers, contract workers and any other person engaged at the workplace who falls within the definition of "employee" under the Act.

COMPLAINTS DURING THE YEAR

3. Complaints Received. The number of complaints of sexual harassment received during the reporting year: [Complaints Received During the Year].

4. Complaints Disposed Of. The number of complaints disposed of during the reporting year: [Complaints Disposed of During the Year].

5. Complaints Pending Beyond Ninety Days. The number of cases pending for more than ninety (90) days as at the close of the reporting year: [Cases Pending More Than 90 Days].

6. Nature of Action Taken. Action taken by the employer on the recommendations of the Internal Committee: [Nature of Action Taken by the Employer].

AWARENESS AND CAPACITY BUILDING

7. Workshops and Awareness Programmes. Number and description of workshops and awareness programmes carried out against sexual harassment during the reporting year: [Workshops / Awareness Programmes Carried Out].

8. Capacity Building of the Committee. Orientation and skill-building undertaken by the members of the Internal Committee during the reporting year: [Capacity Building Undertaken by IC Members].

DECLARATION

9. Confidentiality. This Report does not disclose the name, address, identity or any other particular capable of identifying any complainant, respondent or witness, in accordance with Section 16 of the Act.

10. Statutory Consequence of Non-Submission. The Company records its awareness that failure to constitute an Internal Committee, or to comply with the obligations under the Act including this reporting obligation, attracts penalty under Section 26 of the Act, and that a repeat contravention attracts enhanced consequences including action against the Company's licence or registration.

11. Employer's Annual Return. The particulars in this Report shall also be included in the employer's own annual report where the employer is required to prepare one, and shall otherwise be intimated to the District Officer, as required by Section 22 of the Act.

ACKNOWLEDGEMENT

For the Internal Committee of [Company Legal Name]

[Internal Committee Presiding Officer] Presiding Officer

POSH Annual Report format (India): page one of the document, with each blank to fill in shown in brackets
POSH Annual Report format (India): page one of the document, with each blank to fill in shown in brackets

The provision behind this document

  • Section 4, Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — Ten workers of any kind makes an Internal Committee mandatory, and the external member is where most small committees fail.
  • 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.

Further reading

What the law behind this document actually requires.

  • POSH Compliance Checklist for Indian Startups & SMBs (2026) — A step-by-step checklist to constitute your Internal Committee, draft a compliant POSH policy, train staff, and file the mandatory annual report.
  • POSH compliance at 10 employees: what actually becomes mandatory — Not a policy you write once and file away. A constituted committee, a real annual report, and a headcount nobody is tracking.

Related statutory compliance tools & calculators

  • Headcount Threshold Checker — Verify mandatory Internal Committee obligations for 10+ employees

What this document must contain (Clause-by-Clause Matrix)

POSH Annual Report — Mandatory Clause Matrix & Statutory Protection (2026)
Essential Clause Legal Purpose & Protection Governing Law / Benchmark
The number of complaints received during the calendar year The opening figure everything else is read against. A year with none is stated as none, not left blank. POSH Act, 2013 — s. 21
The number disposed of Received against disposed is the pair that shows whether the Committee is functioning or merely constituted. POSH Act, 2013 — s. 22
The number pending for more than ninety days The Act sets a ninety-day inquiry timeline, so this line exists specifically to surface cases that have run past it. It is the figure a reader looks for first. POSH Act, 2013 — s. 16
The workshops and awareness programmes carried out The Act places an organising duty on the employer, and this is the line where it is evidenced. A blank here is a compliance gap recorded in your own document. POSH Act, 2013 — s. 26
The nature of the action taken by the employer The Committee recommends; the employer acts. The report has to close that loop, described in terms that do not identify anyone. POSH Act, 2013 — s. 21
No particulars capable of identifying any complainant, respondent or witness The Act prohibits publication of identity and of the proceedings. This document leaves the building by design, and in a small team even a role and a date can identify someone. POSH Act, 2013 — s. 22
  • The number of complaints received during the calendar year — The opening figure everything else is read against. A year with none is stated as none, not left blank.
  • The number disposed of — Received against disposed is the pair that shows whether the Committee is functioning or merely constituted.
  • The number pending for more than ninety days — The Act sets a ninety-day inquiry timeline, so this line exists specifically to surface cases that have run past it. It is the figure a reader looks for first.
  • The workshops and awareness programmes carried out — The Act places an organising duty on the employer, and this is the line where it is evidenced. A blank here is a compliance gap recorded in your own document.
  • The nature of the action taken by the employer — The Committee recommends; the employer acts. The report has to close that loop, described in terms that do not identify anyone.
  • No particulars capable of identifying any complainant, respondent or witness — The Act prohibits publication of identity and of the proceedings. This document leaves the building by design, and in a small team even a role and a date can identify someone.

When you need this

  • At the close of every calendar year, once an Internal Committee exists
  • Even in a year with no complaints at all — a nil report is still a report
  • When the employer’s own annual report has to carry the POSH particulars
  • When a client or an investor asks for evidence of POSH compliance beyond the policy document
  • When a District Officer or an inspection asks what was filed for the preceding year

The law that governs it

  • POSH Act, 2013 — s. 21 — The Internal Committee shall prepare an annual report in each calendar year and submit it to the employer and to the District Officer. The particulars it must carry are prescribed in the rules made under the Act.
  • POSH Act, 2013 — s. 22 — The employer shall include in its own annual report the number of cases filed and their disposal, and where the employer is not required to prepare such a report, shall intimate those numbers to the District Officer. The duty therefore runs at two levels, not one.
  • POSH Act, 2013 — s. 16 — The contents of the complaint, the identity and addresses of the complainant, respondent and witnesses, and the conciliation and inquiry proceedings must not be published or made known. The annual report is written to comply with this section, which is why it deals in numbers rather than narratives.
  • POSH Act, 2013 — s. 26 — Failure to comply with the obligations under the Act attracts a fine, and a repeat contravention attracts enhanced consequences, which can extend to action affecting a licence or registration under which the business operates. The reporting duty is one of the obligations this section reaches.

Common mistakes

  • Constituting the Committee, publishing the policy, and then never filing anything again
  • Skipping the filing in a year with no complaints, on the assumption that nothing happened means nothing is owed
  • Naming the complainant or the respondent, or including a detail that identifies them to anyone who works there
  • Reporting on the financial year when the Act speaks of the calendar year
  • Leaving the awareness-programme line blank because none were held, rather than holding them

Frequently asked questions

Do I have to file a POSH annual report if there were no complaints?

Yes. The obligation under s. 21 is annual and does not depend on a complaint having been made. A nil report is filed exactly like any other, and the awareness-programme particulars are due whether or not anyone complained.

Is the report for the calendar year or the financial year?

The calendar year. This is one of the most common errors, because almost every other compliance document an Indian business prepares runs on the financial year.

Who prepares and signs it?

The Internal Committee prepares it, and it is submitted through the Presiding Officer to the employer and to the District Officer. It is the Committee’s report, not management’s, which is part of why it carries weight.

What happens if we have never filed one?

Non-compliance with the Act attracts a fine under s. 26, with enhanced consequences for a repeat contravention. In practice the gap most often surfaces during diligence or an inspection. The remedy is to make sure the Committee is properly constituted, hold the awareness sessions, and file going forward rather than backdating anything.

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