Last Updated: June 2026 | Global Vision Law Firm — New Delhi | ~4 min read
A female employee files a sexual harassment complaint at your company. You have no Internal Complaints Committee. No POSH policy. No training records.
What happens next is not just uncomfortable — it is legally catastrophic.
Under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the employer faces a penalty of up to ₹50,000. On a second violation — cancellation of business licence. And that’s before the reputational damage and civil liability.
POSH compliance is not optional. For every company with 10 or more employees — it is a mandatory legal requirement. And yet, a significant number of Indian companies — including listed companies, startups, and established Delhi-based businesses — still operate without a compliant POSH framework in place.
This guide explains exactly how to implement POSH at your workplace — step by step — and why choosing the best POSH service in Delhi, India makes the difference between paper compliance and genuine protection.
📌 Quick Answer
Implementing POSH at your workplace requires four things: constituting a valid Internal Complaints Committee (ICC) headed by a senior woman employee, drafting and communicating a written POSH policy, conducting mandatory awareness and training sessions for all employees and ICC members, and filing an annual report with the District Officer. The process must be completed as soon as you cross 10 employees — not when a complaint arises. Global Vision Law Firm provides the best POSH service in Delhi, India — from ICC constitution to policy drafting, training, and complaint handling. Contact us today.
💔 Meet Ananya’s Company — A ₹50,000 Penalty and a Licence Warning for a Company That Thought POSH Was “Big Corporate” Stuff
Ananya Kapoor founded a digital marketing agency in Delhi in 2020. By 2024, her team had grown to 34 employees — a mix of permanent staff, freelancers on long-term contracts, and two interns.
In early 2025, a junior designer filed a sexual harassment complaint against a senior account manager.
Ananya had no ICC. No written POSH policy. No training records.
The District Officer inquiry found the company non-compliant on all mandatory requirements. Penalty: ₹50,000 — with a warning that a second violation would trigger cancellation of her GST registration and shop establishment licence.
The complaint itself was ultimately resolved — but the compliance gap had exposed Ananya to consequences that had nothing to do with the merits of the underlying complaint.
POSH compliance isn’t about anticipating complaints. It’s about having the structure in place so that when one arises — and eventually, one does — you’re not simultaneously managing a complaint and a compliance crisis.
⚖️ Part 1: Who Does POSH Apply To?
Every Company with 10 or More Employees
The POSH Act applies to every workplace in India — private limited companies, partnerships, proprietorships, startups, NGOs, and even government bodies — where 10 or more persons are employed.
“Employee” is defined broadly. It includes:
- Permanent and contractual employees
- Part-time employees
- Interns, trainees, and apprentices
- Work-from-home employees
- Consultants engaged on a regular basis
Companies with fewer than 10 employees are not required to constitute an ICC but must still have a basic POSH policy and provide awareness training. Their complaints are handled by the Local Complaints Committee (LCC) constituted at the district level by the government.
🛠️ Part 2: Step-by-Step Implementation — What You Must Do
Step 1 — Constitute the Internal Complaints Committee (ICC)
The ICC is the foundation of POSH compliance. Without a valid ICC, no other compliance step matters.
Mandatory ICC composition:
| Member | Requirement |
|---|---|
| Presiding Officer | A senior woman employee — mandatory. If no senior woman employee is available in your office, nominate one from another branch or unit of the same employer. |
| Minimum 2 Internal Members | Employees committed to the cause of women / with legal knowledge / experience in social work |
| External Member | A person from an NGO or legal background with experience in handling sexual harassment cases |
Critical rules:
- The ICC must have at least 50% women members
- The External Member must be paid a nominal fee for their time
- The ICC must be constituted by a formal written order from the employer — not just verbally designated
- ICC terms are typically 3 years, after which members must be reconstituted
Step 2 — Draft and Communicate the POSH Policy
A POSH policy is a written document that:
- Defines sexual harassment with examples drawn directly from the Act’s definition
- States a clear, unambiguous zero-tolerance position
- Explains the complaint mechanism — how to file, to whom, within what time
- Specifies the ICC’s constitution, names, and contact details
- Outlines the inquiry process and the confidentiality obligation
- Sets out consequences for substantiated complaints
- Addresses false or malicious complaints (which are also a specific provision of the Act)
The policy must be communicated to every employee — not just placed on an intranet. Many companies now include POSH policy acknowledgement in their onboarding documentation.
Step 3 — Conduct Mandatory Awareness and Training
Training is a distinct, mandatory requirement — not something satisfied by sharing a PDF.
Two types of mandatory training:
Employee Awareness Sessions — for all employees (including contractual, part-time, and new joiners). These must explain what constitutes sexual harassment, how to report it, what the complaint process looks like, and that retaliation against complainants is itself a violation.
ICC Member Training — more detailed, covering how to conduct an inquiry, how to maintain confidentiality, the evidentiary standards, the timeline (inquiry must complete within 90 days), and how to write findings and recommendations.
Training must be documented — attendance records, materials used, dates — because the District Officer can request these during an inspection.
Step 4 — Display the Required Information
The Act requires employers to display at conspicuous places in the workplace:
- The names and contact details of all ICC members
- The POSH policy summary
- Penal consequences for sexual harassment
This is often the most visible compliance gap — and one of the first things an inspector checks.
Step 5 — File the Annual Report
Every ICC must submit an annual report to the District Officer containing:
- Number of complaints received during the year
- Number of complaints disposed of
- Number of cases pending beyond 90 days
- Nature of action taken
- Training and awareness sessions conducted
This report must also be disclosed in the Director’s Report under the Companies Act — a requirement introduced by an MCA notification in 2018 that is separate from the POSH Act requirement itself.
📊 POSH Compliance Checklist — At a Glance
| Requirement | Applicable to | Deadline |
|---|---|---|
| Constitute valid ICC | 10+ employees | As soon as threshold is crossed |
| Draft POSH policy | All workplaces | Immediately |
| Communicate policy to all employees | All workplaces | Ongoing — new joiners at onboarding |
| Awareness training for employees | All workplaces | Annually + for new joiners |
| ICC member training | 10+ employees | Before assuming ICC role + annually |
| Display ICC names and contacts | All workplaces | Always visible |
| Annual report to District Officer | 10+ employees | End of each calendar year |
| Directors’ Report disclosure | All companies under Companies Act | In annual Board’s report |
⚠️ 4 Most Common POSH Compliance Gaps in Delhi Workplaces
Gap 1 — No woman presiding officer available. Many companies constitute ICCs without ensuring the presiding officer is a senior woman employee. This is a structural defect that invalidates the entire ICC. The solution — nominate from another branch or unit of the same employer if your own office doesn’t have a senior woman employee.
Gap 2 — No external member. The external member requirement is consistently ignored by companies that treat the ICC as an internal-only committee. Without a valid external member, the ICC is not constituted in compliance with the Act.
Gap 3 — No documentation of training. Training sessions happened but weren’t documented. In an inspection, undocumented training is treated the same as no training. Always maintain signed attendance records, presentation materials, and dates.
Gap 4 — Policy drafted but not communicated. A policy sitting on an intranet page that employees never visit is not “communicated” in the legal sense. Policy acknowledgement at onboarding, email communication with read receipts, and physical display are all part of genuine compliance.
💼 How Global Vision Law Firm Provides the Best POSH Service in Delhi, India
Implementing POSH correctly — with a valid ICC, a compliant policy, documented training, and proper annual reporting — requires experienced legal guidance, not a template downloaded from the internet.
Global Vision Law Firm provides comprehensive POSH implementation services to companies across Delhi, NCR, and India:
ICC Constitution Services: We draft the formal written order constituting your ICC, help identify and onboard a suitable external member, and ensure your ICC composition meets every statutory requirement.
POSH Policy Drafting: We draft customised POSH policies that reflect your company’s specific structure, industry, and workforce — not a generic template.
Training and Awareness Sessions: We conduct live training sessions for employees and specialised training for ICC members — with documentation packages for your compliance records.
Annual Report Filing: We prepare and file the annual report to the District Officer on your behalf.
Complaint Handling Support: When a complaint is actually filed, we advise and assist the ICC through the inquiry process — maintaining procedural integrity and minimising legal risk for the employer.
False Complaint Defence: When a complaint appears to be malicious or fabricated, we advise on the specific POSH Act provisions for addressing false complaints without chilling genuine ones.
If you are looking for the best POSH service in Delhi, India for your company — whether you are setting up from scratch or reviewing an existing framework — Global Vision Law Firm is your trusted partner.
For our dedicated POSH legal services:
- POSH Lawyer Delhi — Sexual Harassment at Workplace & ICC Services
- POSH Policy Compliance Services in Delhi
- Employment — Global Vision Law Firm
📞 +91 9599801188 · +91-11-71522934 📧 globalvisionlawoffice@gmail.com 📍 M-3 Gupta Tower, Azadpur, Delhi – 110033
👉 Contact Us for POSH Compliance Services
❓ Quick FAQs
Q: Does POSH apply to my company if all my employees are men? A: Yes. The POSH Act applies to all workplaces — the Act’s compliance obligations (ICC, policy, training) apply regardless of the current gender composition of your workforce, since the workplace may be visited by women clients, vendors, interns, or contractual workers.
Q: Do work-from-home employees count for the 10-employee threshold? A: Yes. Remote employees are counted toward the total, and the Act’s protections extend to the work-from-home setting, which is treated as an extension of the workplace.
Q: Can the ICC Presiding Officer be a male employee? A: No. The Act specifically requires the Presiding Officer to be a woman employed at a senior level. This is not discretionary.
Q: What happens if a complaint is filed and we don’t have an ICC? A: The matter is referred to the Local Complaints Committee (LCC) at the district level, and the employer simultaneously faces penalty proceedings for non-constitution of the ICC.
Q: How often does the ICC need to be reconstituted? A: ICC members’ terms are typically for a period not exceeding 3 years. Beyond that, fresh appointments must be made by formal written order.
💡 Final Thought
POSH compliance is not a once-done exercise. It is a living, annually renewed, actively maintained framework — ICC, policy, training, documentation, and reporting — that protects your employees, your company, and your business licence.
Ananya’s agency learned this after a ₹50,000 penalty and a licence warning. Every company in Delhi and across India can avoid that outcome by implementing POSH correctly before a complaint arises — not in response to one.
If you’re looking for the best POSH service in Delhi, India to implement or audit your company’s POSH compliance framework — Global Vision Law Firm is ready to help.
👉 Contact Global Vision Law Firm
📞 +91 9599801188
