Is POSH training mandatory in India?

Yes. Section 19(c) of the POSH Act requires employers to organise awareness workshops for employees at regular intervals and orientation programmes for Internal Committee members.

Does POSH training alone make a company compliant?

No. Compliance also requires a validly constituted Internal Committee, a written policy, displayed notices, an annual IC report and action on inquiry findings.

Who needs to comply with the POSH Act?

Every employer. Those with 10 or more employees must constitute an Internal Committee. Complaints from workplaces with fewer than 10 employees go to the Local Committee in the district.

What is the penalty for POSH non-compliance?

Up to ₹50,000 under Section 26, with higher penalties and possible cancellation of the business licence for repeat offences.

POSH Training vs POSH Compliance: What Indian…

POSH training and POSH compliance are not the same thing. Here is what the POSH Act, 2013 requires of employers, and why you need both.

Every few weeks, an HR head tells me, "We are POSH compliant. We did the training last year." I understand why. Training is the most visible part of the law. But a training session, on its own, has never made an organisation compliant. Nor has it made a workplace safe.

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, which we all call the POSH Act, asks for two different things. It asks employers to build a system. And it asks them to keep that system alive through people who understand it. Compliance is the system. Training is how the system comes to life.

What POSH compliance means

Compliance is the set of structures the law requires an employer to have in place, and to be able to prove. In plain terms:

An Internal Committee (IC). Every employer with 10 or more employees must constitute one, by a written order, at each office or unit (Section 4). It is led by a senior woman employee as Presiding Officer, includes at least two employee members and one external member from an NGO or association working on women's issues, and at least half its members must be women.
A written policy. It should cover what sexual harassment is, how to complain, how the inquiry works and what the consequences are.
Visible information. The penal consequences of sexual harassment, and the order constituting the IC, must be displayed at a conspicuous place in the workplace (Section 19(b)).
An annual report. The IC must prepare one every calendar year and submit it to the employer and the District Officer (Section 21). Employers that publish an annual report must also disclose the number of cases in it (Section 22).
Action on findings. When an inquiry concludes, the employer must act on the IC's recommendations within 60 days (Section 13).

Failing to constitute an IC, or to act under Sections 13, 14 and 22, can draw a fine of up to ₹50,000 under Section 26. A repeat offence can double the penalty and put the business licence at risk.

What POSH training means

The law treats training as a duty in its own right. Section 19(c) asks employers to organise workshops and awareness programmes at regular intervals to sensitise employees, and orientation programmes for IC members. Rule 13 of the POSH Rules, 2013 adds capacity-building and skill-building programmes for the IC.

So there are really two kinds of training:

Awareness for everyone. Employees, managers and leadership learn what harassment looks like, where the line sits, how to raise a concern and what happens next.
Orientation and skill-building for the IC. Members learn how to receive a complaint, run a fair inquiry, apply the principles of natural justice, protect confidentiality and write a reasoned report.

Why you need both

A policy that nobody has read protects nobody. An IC that has never been trained is a legal risk dressed up as a safeguard. Its reports can be challenged and its findings set aside. And training without a working system leaves employees aware of their rights but with nowhere credible to take a complaint.

The courts have made this clear. In Aureliano Fernandes v. State of Goa, the Supreme Court found implementation of the POSH Act patchy. It has since issued a series of directions. In August 2025 it ordered a district-wise survey of whether government and private employers have actually constituted their Internal Committees. The direction of travel is unmistakable: regulators are moving from "Do you have a policy?" to "Show us it works."

What "compliant" should look like

When we work with an organisation, we ask three questions:

Is the structure right? A validly constituted IC, a current policy, displayed notices, a calendar for the annual report.
Are the people ready? Employees who know the process, managers who know what to do in the first hour, and an IC that can conduct an inquiry that survives scrutiny.
Is there evidence? Attendance records, assessment results, IC minutes and annual reports, stored where an auditor or a court can see them.

If any one of these is missing, the organisation is exposed. That exposure is legal, and it is human too.

A certificate is not a safe workplace: POSH training vs POSH compliance