Your organization has a POSH policy. But would it pass the audit?”

In our POSH training, we come across many HR teams who are familiar with the policy but a little unsure about the paperwork associated with it.

Here are the most common gaps we see:

IC info is hidden. Section 19 of the POSH Act requires visibility of the composition of the Internal Committee and penalties for harassment to employees. In many offices no one knows where the notice is.

Standalone awareness sessions. A single orientation at hiring is insufficient. The Act provides for a regular awareness program for employees and training for the members of the IC.
No yearly report. The IC shall prepare a report on the complaints received, disposed off and pending and on the programs conducted and submitted to the employer and District Officer.

POSH absent in Board’s Report. Additionally, Companies falling under the Companies (Accounts) Rules will be required to report complaint data in the Board’s Report from July 2025, including cases pending for more than 90 days and the gender composition of their workforce.

IC not registered in SHe-Box. The Ministry of Women and Child Development’s portal is becoming important and some state governments like Delhi have asked organizations to register their ICs. See what applies in your state.

Here’s the uncomfortable truth. A complaint is seldom the first indicator of a compliance problem. There are already the gaps quietly waiting.

✅ A rapid self-check for heads of HR:

• Is our IC notice current and posted?
• Have you confirmed that every IC member’s term is valid and that all members have completed the required training?
• When was our last employee awareness session?
• Is our annual report out?
• So, if you answered “not sure” to even one, it’s worth a closer look.

At POSH INDIA we help organizations in creating compliance that works in practice and not just in paper through IC training, employee awareness sessions and POSH compliance reviews.