PoSH Compliance Checklist for HR Managers: What to Complete Before March 31

March 31 is not just the financial year-end. It is also the deadline by which several important PoSH (Prevention of Sexual Harassment) requirements must be fulfilled, documented, and reported by HR managers and compliance officers.

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 also known as the PoSH Act imposes certain yearly obligations on all employers that have 10 employees or above. Late submission of such deadlines is not only a regulatory risk but this is the risk that will give your organisation a fine of up to Rs. 50,000 in case of the first time and the risk of losing your business licence in case of repeat non-compliance.

This checklist will ensure that you have done everything before the end of the financial year.

Why March 31 Matters for PoSH Compliance

The PoSH Act places the obligation on the Internal Committee (IC) who used to be referred to as the Internal Complaints Committee, to provide an annual report to the employer and in cases concerned to the District Officer. Include all complaints from the reporting period whether calendar or financial year, based on your organization’s reporting cycle.

Since most Indian companies follow the April–March financial year, they should prepare and submit the IC annual report by March 31. Separately, the employer is required to provide PoSH compliance data in the annual report submitted to the Ministry of Corporate Affairs – another March-related deadline of listed and large corporations.

The PoSH Compliance Checklist for March 2026

PoSH compliance checklist infographic with key HR tasks before March 31

1. Internal Committee (IC) Constitution and Review

Ensure that your IC comprises the required minimum number of members: a Presiding Officer (high ranking woman employee), 2 or more people in the workforce and 1 outside member with an NGO or legal background.
Ensure no IC member’s term has expired, members serve a maximum of 3 years and require reappointment through a fresh order.
Make sure that the outside member possesses a valid appointment letter with his/her NGO or legal qualifications recorded.
Ensure that the IC has women members at least 50% as mandated by law.
Revise IC notice board and company intranet with the current member names and contact details.

2. Annual IC Report Preparation

Prepare data on complaints received in FY 2025–26, including the total received, conciliated, inquired into, found valid, and actions taken.
This includes cases that were withdrawn, found to be false, or are pending at year-end.
The Presiding Officer of the IC must sign and date the report.
Send the annual report to the employer (MD/CEO) prior to March 31.
In the case of organisations which employ 10 or more workers, submit the report to the District Officer as required under Section 21 of the PoSH Act

3. PoSH Training Verification

Ensure that all new employees that joined the company during FY 2025-26 have undergone PoSH awareness training.
Ensure that all the IC members have undergone IC-specific training in procedures required in inquiry, natural justice principles, and documentation.
Keep hard copies of attendance or electronic completion certificates of all the training sessions taken.
If you miss any sessions, schedule make-up sessions before the end of March or document a plan to complete them in April.

4. Policy Review and Update

Review your PoSH Policy document it must establish the meaning of sexual harassment, enlist the forbidden behaviours, outline a complaint process, ensure confidentiality and impose penalties.
Check whether the policy covers remote and hybrid workers: It is a compliance loophole that many organisations have stepped into after 2020.
Update the policy regularly to reflect any changes in company structure, locations, or workforce categories added during the year.
Ensure the policy is available to all staff members – on the company intranet, in the employee handbook as well as posted in all workplaces.

5. Documentation Audit

Store current-year complaint files securely and limit access to authorized personnel only.
Keep complaint records of a minimum of 3 years as mandated.
Make sure inquiry proceedings, findings and records of action taken are complete and properly filed.
Create a secret file, record people who accessed complaint files and date.

6. Multi-Location Compliance Check.

In case your organisation functions in more than one city or state, there has to be an IC in each location, or the central IC that is documented to reach. Confirm that:

Every work place having 10 or more employees has a working IC.
The people at the satellite offices or remote locations are aware of the members of the IC and how to complain.
The annual reports address all the locations and not only the registered office.

7. Annual Report Filing (Company Report)

According to the Companies Act, listed and other large privately owned companies should incorporate in the Board Report a disclosure of compliance with PoSH. Assure your Company Secretary that:

The PoSH compliance statement is drafted and reviewed
It is a true replica of the annual report of IC.
It will be included in the Board Report before the AGM.

Quick Reference: PoSH Penalties for Non-Compliance

Violation	Penalty
Failure to constitute IC	Up to Rs. 50,000 fine
Second or subsequent violation	Double the fine + possible cancellation of licence or registration
Failure to submit annual report	Compliance notice from District Officer
Failure to conduct IC inquiry	Inquiry by District Officer, penalty on employer

What Happens If You Are Not Compliant by March 31?

The failure to meet the deadline of an annual report of the IC or the expiry of an IC does not normally have an immediate penalty but it creates documented non-compliance that becomes a liability in three situations; a complaint is filed, a regulatory inspection of your HR compliance or an investor due diligence audit. Across all three cases, a lack of a compliant IC and annual report is treated as a serious compliance gap.

The real solution is: do not wait. Complete the checklist and arrange any outstanding training and file the annual report before the end of the year.

How Transparian Can Help

Transparian offers end-to-end PoSH compliance services: constitution and training of the IC, preparation of annual reports, employee awareness seminars and certification of IC members. In case you have gaps with respect to this checklist, our PoSH team would be able to determine your present position and assist you to seal them before March 31.

FAQ’s

1. Who must comply with the PoSH Act?

All organizations in India with 10 or more employees must comply with the PoSH Act, including constituting an Internal Committee and following reporting requirements.

2. What details must organizations include in the PoSH annual report?

The PoSH annual report must include the number of complaints received, resolved, pending, withdrawn, and actions taken during the reporting period.

3. Is it mandatory to submit the IC annual report to the District Officer?

Yes, organizations with 10 or more employees must submit the IC annual report to the District Officer as per Section 21 of the PoSH Act.

4. s PoSH training mandatory for employees?

Yes, organizations must provide PoSH awareness training to all employees, and they must conduct specialized training for IC members to handle complaints effectively.

5. Does PoSH compliance apply to remote and hybrid employees?

Yes, PoSH compliance extends to remote and hybrid workplaces, and policies must clearly cover virtual interactions and offsite work environments.

6. Which records must organizations maintain under PoSH compliance?

Employers must maintain complaint records, inquiry reports, evidence, and action taken documents for at least 3 years, ensuring confidentiality and restricted access.