In August 2025, the Supreme Court directed a district-wise survey of whether government and private employers have constituted their Internal Committees. For many organisations, that is the moment the POSH question changes. It is no longer "Do we have a policy?" but "Can we prove our system works?"
This checklist is the one we use with organisations to answer that question honestly. Work through it with your HR, legal and IC teams. Every unticked box is a gap worth closing.
Part A: Constitution
- A written order constitutes the IC at every office or unit with 10 or more employees.
- The Presiding Officer is a woman employed at a senior level.
- There are at least two employee members committed to the cause of women or with legal or social work experience.
- There is one external member from an NGO or association committed to women's causes, or a person familiar with sexual harassment issues.
- At least half the members are women.
- No member's term exceeds three years, and the reconstitution dates are on the calendar.
- Vacancies are filled promptly, so that quorum can always be met.
Part B: Policy and visibility
- A written POSH policy is current and approved by management.
- The policy is available in the languages employees use.
- The penal consequences of sexual harassment and the order constituting the IC are displayed at conspicuous places (Section 19(b)).
- IC members' names and contact details are published where every employee can find them.
- Service rules or standing orders treat sexual harassment as misconduct (Section 19(i)).
Part C: Training
- Every new joiner receives POSH awareness training within their first month.
- All employees have attended an awareness programme within the cycle you have defined.
- Managers have completed a manager-specific module.
- Every IC member has completed orientation and skill-building, including a mock inquiry.
- The training covers contract staff, interns and trainees.
Part D: Process readiness
- A complaint intake process exists, including help for complainants who cannot write a complaint themselves.
- A standard inquiry procedure follows Rule 7: timelines, quorum, notices and no legal practitioners.
- Confidential storage is in place for complaint files, minutes and evidence.
- Report templates for inquiry findings are ready.
- A tracker monitors the 90-day inquiry deadline and the employer's 60-day action deadline.
Part E: Reporting
- The IC prepares its annual report for each calendar year, with the Rule 14 contents: complaints received, complaints disposed, cases pending for more than 90 days, workshops held and action taken.
- The annual report is submitted to the employer and the District Officer (Section 21).
- The number of cases is disclosed in the organisation's annual report, or reported to the District Officer where there is no annual report (Section 22).
- For companies, the board's report includes the required POSH disclosures under the Companies Act rules.
What documents should an employer retain after POSH training?
| Record | Why it matters |
|---|---|
| Attendance register or LMS completion report, by date and location | Proves who was trained and when |
| Training content version and trainer details | Shows what was taught, and by whom |
| Assessment results | Evidence that learning was checked |
| Completion certificates issued | Employee-level proof of participation |
| IC orientation and mock inquiry records | Supports the validity of future inquiries |
| Policy acknowledgements | Shows employees received and read the policy |
| Feedback summaries | Inputs for the next cycle's content |
Keep these records together with the IC annual reports. They are the first things an auditor, a District Officer or a court is likely to ask for.