Veritas HR

What is POSH training and who needs it?

POSH training is the workplace awareness programme required by the Sexual Harassment of Women at Workplace Act, 2013. What it covers, who must run it, how often, and what non-compliance costs.

By

Priya Nair

· Updated

POSH training is the workplace awareness programme that Indian employers are required to run under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — the Act everyone shortens to POSH. It is not one fixed course: in practice it means two things at once — a session for the general workforce explaining what sexual harassment is and how to complain about it, and a separate, longer session for the people who sit on the Internal Committee and will have to conduct an inquiry. If you have been asked for a “POSH certificate” by a client, an auditor or an investor, this is what sits behind the request.

The law behind it

The POSH Act came into force in December 2013 and was drawn from the Supreme Court’s Vishaka guidelines. It defines sexual harassment, sets out where a complaint goes, and puts a list of duties on the employer. The training obligation sits in section 19, which requires an employer to organise workshops and awareness programmes at regular intervals to sensitise employees, and to run orientation programmes for the members of the Internal Committee.

Two features surprise people. First, the Act protects an “aggrieved woman” at the workplace, which is wider than your payroll: interns, apprentices, contract and agency workers, consultants and even visitors are covered. Second, “workplace” is defined broadly enough to include client sites, off-site meetings and travel arising out of employment. The Act protects women; a gender-neutral internal policy is permitted on top of it but does not replace the statutory machinery.

Who has to comply

Every workplace with ten or more employees must constitute an Internal Committee. The count is not restricted to permanent staff, and the committee is required at each office or administrative unit, not once per company — a firm with three branches generally needs three committees. There is no industry carve-out and no exemption for start-ups, non-profits or partnerships.

The committee must be chaired by a woman employed at a senior level, include at least two employees preferably with legal knowledge or experience of social work, and include one external member drawn from an NGO or association committed to women’s causes, or a person familiar with sexual harassment issues. At least half the members must be women, and members serve for a term of up to three years. Below ten employees, or where the complaint is against the employer, the complaint goes instead to the Local Committee constituted by the District Officer for that district.

What the training actually covers

For employees, a competent session covers the statutory definition of sexual harassment and the five listed behaviours; the circumstances the Act treats as harassment, such as implied threats about employment status; what the workplace covers, including client sites and work travel; how to file a written complaint and the three-month window for doing so; who sits on your Internal Committee and how to reach them; the protection against retaliation; and the consequence of a complaint made knowingly falsely. Sessions should run in the language of the workforce; the rules expect awareness material in a language employees actually understand, which matters on shop floors and in field teams.

For Internal Committee members, the session is procedural rather than motivational. It deals with receiving and recording a complaint, the conciliation route the complainant may request (which cannot be settled for money), the committee’s civil-court powers over evidence and attendance, interim relief such as transfer or leave, the ninety-day limit on completing an inquiry and the sixty-day limit on the employer acting on the recommendations, confidentiality, and how to write findings that will survive an appeal. Members who have only sat through the employee session are rarely equipped to run an inquiry, and a badly run inquiry is the most common way an employer loses on appeal.

How often it has to happen

The Act says “at regular intervals” and does not name a number. The working norm, and what auditors ask for, is one awareness session a year for all staff, a session for new joiners at induction, and a refresher for the Internal Committee whenever its composition changes. Whatever cadence you choose, keep dated attendance sheets: the annual report is easier to write and an audit easier to answer with a record rather than a policy PDF.

The annual report

The Internal Committee must prepare an annual report for each calendar year and submit it to the employer and to the District Officer. It records the number of complaints received and disposed of, the number pending beyond ninety days, the workshops and awareness programmes carried out, and the nature of action taken. Companies incorporated under the Companies Act have a parallel obligation to state in the board’s report that they have complied with the provisions relating to the constitution of an Internal Committee.

How the report is actually filed varies. The District Officer is notified by the state government, and several states have added their own registration or online reporting steps on top of the central Act, so the route in Gujarat is not necessarily the route in Karnataka or Maharashtra. Confirm the current filing channel for your state rather than assuming a nil return by email will do.

What non-compliance costs

Section 26 makes failure to constitute an Internal Committee, failure to act on the committee’s recommendations, failure to file the annual report or any other contravention of the Act punishable with a fine of up to ₹50,000. A repeat offence attracts twice that punishment, and — the part that tends to focus attention — can lead to cancellation of the registration or licence required to carry on the business, or to its withdrawal or non-renewal. Breach of the confidentiality the Act imposes is dealt with separately through service rules.

The commercial cost usually bites first: large customers ask for POSH evidence during vendor onboarding, and funding and acquisition diligence routinely asks for the constitution order, the policy, training records and the last annual report.

What a good training provider gives you

  • A named trainer with a documented background in inquiries, not a slide deck delivered by a generalist.
  • Separate employee and committee sessions, priced separately, in the languages your workforce speaks.
  • A dated attendance record and a certificate you can hand to an auditor.
  • A policy drafted for your organisation, with the committee’s names and contact details in it, and the display notices the Act requires.
  • An external Internal Committee member on retainer, if you do not already have one, with clarity on whether attendance at inquiry meetings is included.
  • Help drafting the annual report, and a stated position on inquiry support when a complaint is actually filed.

Ask for references from employers of your own size and sector.

This is general information, correct as at September 2026, and not legal advice. Thresholds, filing routes and state-level requirements change; confirm your position with a consultant or lawyer before acting.

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