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When Is the POSH Annual Report Due in India 2026

LexComplyLexComply7 min read
posh annual report posh annual report format posh annual return annual report under posh act posh annual report due date

TL;DR

  • The POSH annual report has no national due date.
  • Section 21 of the Sexual Harassment of Women at Workplace Act 2013 requires the Internal Committee to prepare one each calendar year and submit it to the employer and the District Officer, and District Officers may set a filing date by notice: New Delhi asked for 31 January 2024 (for 2023) and Gurugram for 28 February 2026 (for 2025).
  • Rule 14 fixes five contents, and companies repeat three of them in the Board's report.

Quick Answer: The POSH annual report has no national deadline; District Officers may set one by notice, as Gurugram did for 28 February 2026. Section 21 of the POSH Act requires the Internal Committee to prepare it every calendar year. It goes to the employer and the District Officer, with five contents fixed by Rule 14.

The annual report is one of the few recurring filings under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013, known as the POSH Act. It is the Internal Committee's report, not the employer's, but the employer must carry its numbers into its own annual report. Companies now repeat three of them in the Board's report.

POSH annual report at a glance

Point Position Provision
Who prepares it The Internal Committee, or the Local Committee Section 21(1)
How often Each calendar year Section 21(1)
Submitted to The employer and the District Officer Section 21(1)
Due date Not fixed by the Act or Rules; some District Officers set one by notice Section 21(1); Rule 14
Contents Five items Rule 14
Employer's own report Number of cases filed and disposed of Section 22

When Must the POSH Annual Report Be Filed?

Each calendar year, by any date the District Officer sets by notice. Section 21(1) of the POSH Act requires the report "in such form and at such time as may be prescribed", but Rule 14 prescribes only its contents. No national calendar date exists.

What Dates Have Districts Set?

District practice varies, so the date has to be checked for each district where the employer has a workplace.

District Report for Asked by Mode
New Delhi Calendar year 2023 31 January 2024 Online, with a signed copy uploaded
Gurugram, Haryana Calendar year 2025 28 February 2026 Email from the organisation's official address

A 31 January date is therefore a district instruction where it appears, not a requirement of the Act.

Does the SHe-Box Portal Change the Deadline?

No. The Ministry of Women and Child Development's SHe-Box portal lets organisations submit the annual report to the District Officer online, and its FAQ says onboarding is mandatory for all workplaces. That is portal guidance; the deadline still comes from the District Officer. Where a district instruction is unclear, advisory services can help you interpret it.

What Must the POSH Annual Report Contain?

Rule 14 of the POSH Rules 2013, notified as G.S.R. 769(E) of 9 December 2013, lists five details.

Rule 14 item What it reports
(a) Number of complaints of sexual harassment received in the year
(b) Number of complaints disposed of during the year
(c) Number of cases pending for more than ninety days
(d) Number of workshops or awareness programmes against sexual harassment carried out
(e) Nature of action taken by the employer or the District Officer

A nil report still covers all five items. Rule 14 sets no format beyond them, so a district may ask for its own template or portal fields. Treat it like the other employer registers and returns that recur each year.

Where Is the POSH Annual Report Submitted?

To two places: the employer and the District Officer, under section 21(1). The District Officer then forwards a brief report on all annual reports received to the State Government, under section 21(2).

What Must the Employer Do With It?

Section 22 requires the employer to include the number of cases filed and their disposal in the annual report of its organisation. Where no such report is prepared, the employer intimates the numbers to the District Officer instead.

Which Workplaces Need an Internal Committee?

Every employer must constitute an Internal Committee under section 4(1), at each office or administrative unit. A workplace with fewer than ten workers is covered by the district's Local Committee under section 6(1). The full applicability test is set out in the guide to who must comply with the POSH Act.

What Must a Company Disclose in Its Board's Report?

Rule 8(5)(x) of the Companies (Accounts) Rules 2014, as amended by G.S.R. 357(E) of 30 May 2025 with effect from 14 July 2025, requires two things of every company other than a One Person Company or small company (Rule 8(6)):

  • a statement that the company has complied with the provisions on constituting the Internal Complaints Committee;
  • three of the Rule 14 numbers: complaints received, complaints disposed of, and cases pending for more than ninety days.

Rule 8(6) excludes a One Person Company and a small company from this Board's report rule. A template that states compliance without the three numbers predates the 2025 amendment. Compliance reporting across entities lets you pull the three numbers for each company from one record.

What Happens If the Annual Report Is Not Filed?

An employer that fails to act under section 22 is punishable with a fine of up to ₹50,000 under section 26(1)(b). Non-filing of the Committee's report is commonly treated as a contravention under section 26(1)(c), and district notices such as New Delhi's warn of the same penalty. State drives such as the Maharashtra 30-day POSH compliance audit add to that enforcement pressure.

Default Consequence Provision
First conviction Fine up to ₹50,000 Section 26(1)
Repeat conviction for the same offence Twice the punishment, up to the maximum Section 26(2)(i)
Repeat conviction Cancellation or non-renewal of licence or registration Section 26(2)(ii)

How Is the POSH Calendar Tracked Across Locations?

A national employer can owe reports to many District Officers, each with its own date and mode. A compliance management platform holds each district's date, the Committee's report and the District Officer acknowledgement as evidence.

LexComply does not file reports with District Officers; the Internal Committee and the employer do. You can get in touch to see how district dates would be tracked.

Common Mistakes to Avoid

  • Treating 31 January as the law. Section 21(1) and Rule 14 fix no date; District Officers may set one by notice, and Gurugram asked for 28 February 2026.
  • Saying Rule 14 sets the timing. Rule 14 lists contents only; the words "at such time as may be prescribed" are in section 21(1).
  • Using a pre-2025 Board's report template. Rule 8(5)(x), as amended from 14 July 2025, adds the three complaint numbers.
  • Skipping a nil year. Section 21(1) requires a report each calendar year, including a year with no complaints.
  • Filing only with the District Officer. Section 21(1) requires submission to the employer as well, and section 22 requires the employer to report the case numbers.
  • Stating a 10-employee test under section 4. Section 4(1) has no number; workplaces with fewer than ten workers fall to the Local Committee under section 6(1).

This article is general information on Indian workplace law, current as at the date shown above. It is not legal advice and does not take account of any particular employer's facts. Obtain professional advice before acting on any position described here.

Frequently Asked Questions

Is the POSH annual return the same as the annual report?
Yes. "Annual return" is the common name for the annual report the Internal Committee prepares under section 21 of the POSH Act. It is one document, covering the five Rule 14 items, submitted to the employer and the District Officer for each calendar year.
Is there a prescribed POSH annual report format?
No national form exists. Rule 14 prescribes only five contents: complaints received, disposed of and pending over ninety days, workshops held, and action taken. A District Officer may ask for a specific template, portal fields or a signed copy, so check the district's notice.
Does a company with no complaints file a POSH report?
Yes. Section 21(1) requires the Internal Committee to prepare an annual report each calendar year, so a nil report is filed with zeros against the Rule 14 items. Companies other than One Person Companies and small companies also state the nil figures in the Board's report under Rule 8(5)(x).
Can the report be sent to the District Officer by email?
It depends on the district. Gurugram accepted reports for 2025 only by email from the organisation's official address, while New Delhi asked for online filing with a signed copy uploaded. The mode, like the date, comes from the District Officer's notice.
Does an employer with offices in several districts file several reports?
Usually yes. Section 4(1) requires an Internal Committee at each office or administrative unit, and each Committee reports to the District Officer of its district. The employer's own report under section 22 then aggregates the cases filed and disposed of across all locations.

About the Author

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