If your company, startup, NGO or institution has 10 or more employees and does not yet have a properly constituted Internal Committee (ICC) and POSH policy — you are exposed to penalties of up to Rs 50,000 (doubling to Rs 1,00,000 for repeat violations), and any disciplinary action you take could be challenged as legally invalid. We help you set up, fix, or reconstitute your complete POSH compliance framework — correctly, and on time.
Already facing a sexual harassment complaint or allegation at your workplace? This page covers compliance setup — for individual complaint handling, ICC inquiry representation, or defense matters, visit our dedicated page: POSH Lawyer Delhi — Sexual Harassment Cases & ICC Defense →
Call now: +91 9599801188
Under the POSH Act 2013, every employer with 10 or more employees at any single office or branch — across all sectors: private companies, startups, NGOs, educational institutions, hospitals and government offices — must constitute an Internal Committee and maintain a written anti-sexual harassment policy.
Permanent, temporary, contract staff, interns and probationers are all counted. Many companies discover they crossed the threshold months ago without realising compliance had become mandatory.
If you operate from multiple locations, each office or branch with 10+ employees requires its own Internal Committee — a single head-office ICC is often not sufficient.
The Delhi High Court has confirmed that digital communications and remote work arrangements fall within POSH jurisdiction — your policy and ICC must account for this.
If your establishment has fewer than 10 employees, complaints route to the government's Local Committee — but having a clear internal policy is increasingly expected during investor due diligence, client audits and tenders.
A mid-size company had an Internal Committee constituted on paper. The Presiding Officer had left the organisation eight months earlier, and nobody reconstituted the committee. When a complaint was filed, the entire inquiry was challenged on the ground of improper constitution of the ICC. The proceedings were invalidated, and the employer received a show-cause notice from the District Officer.
Across India, many organisations have a POSH policy and ICC only on paper — members who have left, terms that lapsed years ago, no external member, or a policy that was never actually circulated to employees. In 2025-26, the Supreme Court directed district-wise surveys of ICC constitution, meaning state authorities are actively checking. A compliance review today is far cheaper than discovering the gap during a live complaint.
Use the form on this page, or call us — we will walk through a short checklist covering ICC composition, term validity, policy status, training records and annual filings, and tell you exactly where you stand.
A legally sound POSH framework is not just one document — it's an ongoing system with five core components.
Properly constituted Internal Committee with valid Presiding Officer, internal members and external member
Written anti-harassment policy, drafted, approved and circulated to all employees
Regular awareness sessions for all staff — recommended every 6 months, quarterly for managers
Section 21 / Rule 14 annual report to the District Officer on complaints received and resolved
Sexual harassment complaint data disclosed in the Board's Report (Companies Act entities)
The ICC's composition is strictly defined by law. Getting this wrong is the single most common reason an inquiry gets challenged.
A senior woman employee from the same workplace, heading the committee
Employees committed to the cause of women, or with legal/social work experience
From an NGO or association working on women's issues, or with relevant legal knowledge
At least half of all ICC members must be women, including the Presiding Officer
Each ICC member serves a maximum term of 3 years. When a member resigns, is transferred, or their term lapses, the committee must be reconstituted promptly — an ICC operating with an expired or vacant Presiding Officer / external member seat is not validly constituted, and any inquiry it conducts can be challenged on this ground alone.
The external member requirement is the single most commonly missed element. We provide qualified external member services for ICCs — fulfilling the legal requirement with a member who brings genuine legal knowledge of POSH proceedings to your committee's inquiries.
Penalties under the POSH Act are real, and 2025-26 enforcement has intensified significantly.
An inquiry conducted by an improperly constituted ICC can be set aside entirely — meaning any disciplinary action you took (termination, warning, etc.) based on that inquiry becomes legally vulnerable. The District Officer can also issue show-cause notices, and in 2025-26 the Supreme Court has directed state-wide verification surveys of ICC constitution across India.
A structured approach whether you're starting from scratch or fixing an existing ICC.
We review your current ICC composition (if any), policy documents, training records and filing history against the legal requirements, and identify every gap.
We help you identify and appoint a Presiding Officer, internal members, and provide a qualified external member — ensuring the 50% women requirement and proper documentation of appointments.
We draft a comprehensive anti-sexual harassment policy tailored to your organisation — covering definitions, complaint procedure, timelines, confidentiality, and remote/hybrid work — ready for board approval and circulation.
We conduct training sessions for employees and managers covering the policy, complaint mechanisms, and what constitutes prohibited conduct — with attendance records maintained for compliance purposes.
We assist with preparing and filing the Section 21 annual report to the District Officer, registering your ICC on the SHe-Box portal where applicable, and preparing Board's Report disclosures.
We track your ICC's 3-year term and member changes, and proactively reach out when reconstitution is due — so your compliance never lapses again.
Whether you need everything from scratch or just one missing piece, we can help.
Complete setup of a legally compliant Internal Committee for organisations that have never had one — covering composition, appointment documentation, and notification to employees.
Get Started →If your existing ICC has lapsed members, an expired term, or vacant seats, we help you reconstitute it correctly — and review whether any prior inquiries need to be revisited.
Get Started →We provide qualified external members for your ICC — fulfilling the mandatory legal requirement with someone experienced in POSH inquiries and procedure.
Get Started →A comprehensive, India-specific anti-sexual harassment policy covering definitions, complaint mechanisms, timelines, confidentiality and remote-work provisions — ready for board approval.
Get Started →In-person or virtual awareness sessions for employees and ICC-specific training for committee members on conducting fair, legally sound inquiries.
Get Started →Preparation and filing of the Section 21 annual report to the District Officer, and registration of your ICC on the SHe-Box portal where mandated.
Get Started →Helping companies prepare accurate sexual harassment complaint disclosures in the Board's Report under the 2025 Companies (Accounts) Second Amendment Rules — avoiding the Rs 3,00,000 penalty.
Get Started →A comprehensive audit of your existing framework — ICC validity, policy adequacy, training records, filing history — with a written gap report and remediation plan.
Get Started →If a complaint arises during or after your compliance setup, we can support your ICC through the inquiry, or represent the complainant or respondent — handled by a separate, dedicated team.
See Complaint & Defense Services →Run through this checklist — if you're unsure about any item, that's a sign a compliance review would help.
Multi-location ICC setup and centralised compliance management
First-time ICC formation as you cross the 10-employee threshold
Compliance frameworks suited to non-profit governance structures
POSH and HEI-specific compliance for colleges and universities
ICC formation across medical and administrative staff structures
Compliance for factory floor and administrative staff across plants
Compliance frameworks designed by lawyers who also handle real POSH inquiries.
Because our team also represents complainants and respondents in actual ICC inquiries, we know exactly which composition errors, policy gaps and procedural mistakes get an inquiry thrown out — and we build your framework to avoid them.
We don't just tell you that you need an external member — we provide one, solving the most commonly missed compliance requirement in a single step.
We don't disappear after the initial setup — we track your ICC's 3-year term and proactively flag when reconstitution, retraining or refiling is due.
From the Companies (Accounts) Second Amendment Rules 2025 Board disclosure requirement, to the Supreme Court's 2025-26 district-wise ICC verification directive, to Delhi High Court rulings on remote-work coverage — our frameworks reflect the current legal landscape.
Compliance setup is quoted as a fixed scope of work after the free review — no open-ended hourly billing for a process that should have a defined start and end.
Feedback from organisations we've helped become fully compliant.
"We had crossed 10 employees almost a year before we realised POSH compliance had become mandatory. Global Vision Law Firm helped us set up our ICC, draft our policy, and run our first training session — all within a couple of weeks. The external member service was especially helpful since we had no idea where to find one.
"Our ICC had been constituted years ago but two members had since left the company. We didn't realise this made our committee invalid until our compliance review with this firm. They reconstituted it properly and now send us reminders well before terms expire.
"As an NGO, we wanted to make sure our internal policies matched the standards we advocate for externally. The team drafted a thorough policy and conducted training that our staff found genuinely useful, not just a box-ticking exercise.
Common questions from HR teams, founders and compliance officers.
Yes. Under the POSH Act 2013, every employer with 10 or more employees at any office or branch must constitute an Internal Committee (IC, commonly called ICC) and have a written anti-sexual harassment policy. This applies to all sectors — private companies, startups, NGOs, educational institutions, hospitals and government offices. The count of 10 includes permanent, temporary, contract, intern and probationary employees.
Under Section 26 of the POSH Act, failure to constitute an ICC, failure to act on its recommendations, or any other contravention can attract a fine of up to Rs 50,000 for a first offence, doubling to Rs 1,00,000 for repeat violations, with potential cancellation or non-renewal of business licences and registrations. Beyond fines, courts have held that an inquiry conducted by an improperly constituted ICC is legally invalid, which can collapse an entire disciplinary action if challenged.
The ICC must have a minimum of four members: a Presiding Officer who is a senior woman employee, at least two internal members committed to the cause of women or with relevant legal/social work experience, and one external member from an NGO or association working on women's issues, or with relevant legal knowledge. At least half of all members should be women. The ICC's term is a maximum of three years, and committees must be reconstituted when members leave or terms expire.
Any organisation that crosses the threshold of 10 employees — including contract staff, interns and probationers — must comply, regardless of whether it is a startup, SME, or large corporation. For establishments with fewer than 10 employees, complaints are handled by the government-constituted Local Committee (LCC), but having a clear internal policy is still good practice and increasingly expected by clients, investors and partners during due diligence.
Beyond initial formation, employers must: conduct regular employee awareness training (recommended at least every six months, with quarterly sessions for managers under 2026 guidance); file an annual report under Section 21 and Rule 14 to the District Officer detailing the number of complaints received and resolved; disclose sexual harassment complaint data in the Board's Report under the Companies (Accounts) Second Amendment Rules 2025 (effective 14 July 2025); register the ICC on the SHe-Box portal where mandated by the state; and reconstitute the ICC every three years or when members become ineligible.
Yes, and this combined expertise is valuable. A firm that regularly represents complainants and respondents in POSH inquiries understands exactly how committees are scrutinised, what makes an ICC's constitution or procedure vulnerable to challenge, and where most organisations' policies fall short. Global Vision Law Firm provides both compliance setup services for employers and representation in individual POSH matters — see our POSH Lawyer Delhi page for individual complaint and defense matters.
For an organisation starting from scratch, ICC formation, policy drafting and an initial training session can typically be completed within 1-3 weeks, depending on how quickly internal member nominations are finalised. Annual report filing and SHe-Box registration follow once the ICC and policy are in place. We provide a clear timeline as part of your free compliance review.
Our free review covers a short checklist: whether your ICC is properly constituted with valid member terms, whether your policy exists and has been circulated, whether training has been conducted in the last 12 months, and whether annual reports and SHe-Box registration are up to date. You'll receive a clear, written summary of any gaps and a fixed-scope proposal to address them — with no obligation to proceed.
Get a free, confidential review of your organisation's POSH compliance status — ICC, policy, training and filings — and a clear plan to close any gaps.
As per the rules of the Bar Council of India, law firms are not permitted to solicit work and advertise. By clicking the "Agree" button and accessing this website, the user fully accepts that you are seeking information of your own accord and volition and that no form of solicitation has taken place by the Firm or its members. Also, the information about us is provided to the user only on his/her specific request and any information obtained or materials downloaded from this website is completely at the user’s volition and any transmission, receipt or use of this site would not create any lawyer-client relationship.
The information provided under this website is solely available at your request for informational purposes only, should not be interpreted as soliciting or advertisement. We are not liable for any consequence of any action taken by the user relying on material / information provided under this website. In cases where the user has any legal issues, he/she in all cases must seek independent legal advice.