PoSH Complaints in Indian IT Companies Have Nearly Quadrupled Here’s What’s Going Wrong

Sexual harassment complaints in India’s IT sector have risen sharply over the last four years, not by a small margin, but by close to four times the pre-pandemic baseline. The question most HR teams are not asking loudly enough is: why?

The easy answer is that better awareness leads to more reporting. That is partially true. But it does not explain why so many of those complaints are being mishandled, delayed, or closed without any satisfactory outcome. That is a different problem and it points to structural gaps in how Indian IT companies have approached PoSH compliance altogether.

Understanding the Numbers

Data from annual labour reports and industry surveys consistently shows the same pattern. Formally reported workplace harassment complaints in tech companies, those logged through the Internal Complaints Committee (ICC)  have increased roughly 3.5 to 4 times between 2020 and 2025. This holds across large IT services firms, mid-sized product companies, and funded startups.

Two responses tend to follow this data. First, higher complaint numbers reflect improved employee awareness. Second, this means the system is working.

Both are partially right. A more connected, informed workforce is more willing to report. But an increase in complaints without a corresponding improvement in how they are handled is not progress. It is a backlog problem and it deserves to be treated as one.

What Is Actually Going Wrong

1. The ICC Exists on Paper Only

Of all the PoSH compliance gaps that come up in audits, ICC-related failures are the most consistent. A company forms the committee during onboarding or when a consultant asks them to. The composition looks correct on a spreadsheet. And then nothing else happens.

Common ICC failures include:

• The committee was formed but has never held a meeting
• The external member was appointed once and has had no contact with the company since
• The Presiding Officer changed roles or left, and the records were never updated
• ICC members have no understanding of how to conduct an inquiry

When a complaint finally arrives, the committee does not know how to proceed. Timelines slip past the 90-day window the law requires. Neither the complainant nor the respondent receives clear communication. And what was meant to be a structured process ends up looking arbitrary to everyone involved.

The ICC is not a compliance checkbox. Under the PoSH Act, it functions as a quasi-judicial body. Its members need proper training before they can handle complaints in a way that holds up legally and that training needs to happen before a complaint is filed, not after.

2. Hybrid Work Changed What “Workplace” Means And Most Policies Have Not Caught Up

The PoSH Act, 2013 was designed for physical workspaces. Then offices went hybrid, and the boundaries of what counts as a workplace interaction stretched in ways the law did not originally anticipate.

Harassment now happens through:

• Team messaging platforms like Slack or Teams
• WhatsApp conversations outside work hours
• Comments during video calls, often without any manager present
• Informal group chats on personal devices

Most companies have not updated their sexual harassment policies since 2020. The policy sitting on the intranet still refers to office premises and in-person meetings. An employee filing a complaint about a Slack message or a late-night WhatsApp conversation finds that the process was never designed to handle what they are describing.

This is not a minor gap. It is one of the more direct reasons why complaints are rising while resolution rates are not keeping pace.

3. PoSH Training for Employees Has Not Kept Pace With Growth

IT companies hire fast and lose people fast. The employees who attended an awareness session in January may look nothing like the workforce in November. Yet most companies still treat PoSH training as a once-a-year event, one session, usually in the first quarter, attended by whoever did not find a reason to skip it.

The gaps this creates are predictable:

• New joiners receive a rushed induction session and little else
• Contract staff, third-party vendors, and remote consultants are frequently excluded entirely
• Distributed teams in different cities may never receive consistent messaging
• Employees promoted into management roles receive no additional guidance on their changed obligations

Under the PoSH Act, awareness programmes are a legal requirement  not an optional add-on. A single annual session may meet the minimum on paper, but it does not create the kind of sustained awareness that reduces incidents or improves complaint handling. For more on why this matters, see why one-time PoSH training for employees is not enough.

4. Leadership Has Handed This Off to HR and Stepped Away

One pattern that appears repeatedly in organisations with high complaint rates and poor resolution outcomes: senior leadership treats PoSH as an HR department responsibility and considers its own obligation discharged.

The CHRO or HR head is handed the compliance mandate. They run the training, maintain the ICC records, and file the annual report. Leadership is rarely involved beyond that.

The problem is that workplace safety is a culture issue first and a documentation issue second. When employees see that a senior manager with an active complaint against them continues in their role while the matter is “under review” for months, no training session corrects that signal. The number of complaints filed reflects how safe employees feel, not just whether a policy exists.

The ICC also needs active backing from management to function properly. Without it, committees become reluctant to issue findings against senior employees and complainants know this before they even file.

5. Retaliation After Complaints Is Harder to Detect and More Common

Retaliation against complainants is illegal under the PoSH Act. But in a hybrid work environment, it does not look the way it used to.

It looks like:

• Being quietly removed from project updates or team communications
• Receiving vague, unhelpful feedback during the next appraisal cycle
• A team reassignment framed as a “restructuring”
• Reduced visibility in meetings without any explicit reason given

In a physical office, colleagues could observe this kind of treatment. In distributed teams, it is nearly invisible. Organisations that do not have explicit anti-retaliation procedures separate from the main sexual harassment policy are exposed to this pattern in ways they often do not recognise until a second complaint is filed.

6. The Annual PoSH Report Is Consistently Being Missed

Under the PoSH Act, every organisation with 10 or more employees must submit an annual report to the District Officer by January 31. The report must include:

• Number of complaints received during the year
• Number of complaints disposed of within the 90-day window
• Complaints pending beyond 90 days
• Training programmes conducted during the year

Many IT companies, particularly mid-sized ones, still do not file this consistently. A common misconception is that the report is only required when a complaint is received. It is not. The obligation exists every year, regardless of whether anything was filed.

Non-filing is a violation under Section 26 of the Act and attracts penalties. More practically, it means there is no external record that the organisation’s PoSH framework is functioning which creates additional exposure if a matter ever escalates to the Local Complaints Committee or reaches a court. A structured PoSH compliance checklist can help make sure this deadline does not get missed year after year.

What IT Companies Need to Do Differently

Complaints nearly quadrupling is not a problem that better messaging can fix. It reflects real structural gaps in how the sector has built or failed to build a functional PoSH framework.

The IT sector has specific characteristics that make this harder: rapid hiring, high attrition, flat hierarchies, distributed teams, and a culture that tends to move fast. None of that excuses compliance failure, but it does explain why a generic off-the-shelf programme rarely works.

What actually works looks like this:

• Building the ICC as a real, trained, functional body, not a name on a spreadsheet
• Updating sexual harassment policies to explicitly cover digital and remote interactions
• Conducting role-based PoSH training for employees, managers, and ICC members separately, since each group carries different obligations under the law
• Filing the annual report every year, not only in years when complaints were received
• Working with an experienced PoSH consultant to audit the existing framework and close gaps before they become liabilities

Most of the common PoSH compliance mistakes that lead to audit failures or escalated complaints are not difficult to fix. They are simply easy to overlook when nobody is actively tracking them. The organisations that handle this well are not necessarily the ones where incidents never occurred, they are the ones with a working ICC, consistent training, and a process that employees actually trust.

Let Transparian Simplify Your PoSH Compliance

From managing ICC constitution and PoSH training for employees to annual report filing and ongoing awareness programmes, Transparian provides expert PoSH Compliance support for HR teams and business owners. Through reliable compliance services and experienced PoSH consultants, Transparian helps growing businesses stay audit-ready, penalty-free, and fully aligned with every requirement under the PoSH Act, 2013.

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