What is the POSH Annual Return?
Section 21 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act, 2013) requires every organisation to prepare and submit a POSH Annual Return or Report to the District Officer (DO). The POSH Annual Report is prepared by the Internal Committee (IC) and submitted to the employer who then submits a copy to the District Officer.
This is the primary accountability mechanism under the POSH Act. It is a structured record of how many complaints the organisation received, how many were resolved, how many are still pending, and whether the IC is properly constituted. Skipping it, or submitting an incomplete version is treated as non-compliance under Section 26.
Who Must File the POSH Annual Return?
Any organisation with 10 or more employees, private, public, or NGO, must file their POSH Annual Report through its IC. This covers IT companies, manufacturing, retail, healthcare, education, and the unorganised sector equally.
Two things that catch organisations off guard. First, POSH compliance requires filing even in years where zero complaints were received. A NIL report is still mandatory. Second, the obligation applies to each branch or unit that has its own IC. Offices in three different districts mean three separate filings, one for each District Officer.
What Must the Annual Report Include?
Rule 14 of the POSH Rules, 2013, lays down the POSH Annual Report format. Every IC-prepared report must cover:
- Number of complaints received during the year
- Number of complaints disposed of
- Cases pending for more than 90 days, with reasons
- Number of awareness programmes and workshops conducted
- Details of training provided to IC members
The Report must also confirm the current composition of the IC, including their names, designations, and roles of all members, including the external member. Some District Officers ask for supporting documents like appointment letters for IC members or records from awareness sessions. Requirements can vary by district, so a quick check with the relevant DO’s office before submitting is worthwhile.
POSH Annual Return Due Date & Deadlines
The POSH Act does not set a single national deadline. Submission windows are notified at the state or district level, so they vary across the country, sometimes significantly.
31 January is the most widely followed cutoff, but it is not universal. Gurugram’s District Officer consistently sets the deadline at 28 February. Certain districts in Maharashtra and Telangana have used different windows in earlier years. The safest approach is to check the current notification issued by your specific District Officer.
Since the POSH Annual Return covers the previous calendar year (January to December), organisations should begin compiling complaint data, awareness records, and IC composition details in December itself. Scrambling in January is avoidable, and late filing, however minor it seems, has consequences.
Where to Submit Your Annual Report
Submission goes to the District Officer (DO) for the district where the workplace is located. Who qualifies as the DO varies by state. It may be the District Collector, the District Magistrate, or a designated officer under the Labour Department. Our District Officer address directory has submission contacts for major cities across India.
Digital submission is increasingly accepted, including email or a Google Form shared by the DO’s office, depending on the district. For organisations with operations across multiple states, SHe-Box 2.0 offers a centralised portal. From 2025, IC registration on SHe-Box 2.0 is mandatory, so that step must be completed before any online submission is attempted.
New MCA Amendment 2025: Board-Level POSH Disclosure
From July 2025, POSH obligations move into the boardroom. A Ministry of Corporate Affairs amendment requires companies to include POSH-related disclosures in their annual Board Report. This applies to all companies registered under the Companies Act, 2013, and not just listed entities. Private limited companies are included.
The Board Report must now state:
- That the company has complied with the provisions of the POSH Act, 2013
- That an IC has been duly constituted
- The number of complaints received and disposed of during the financial year
- The number of complaints pending at the close of the financial year
Directors are now accountable at the board level. Organisations that have been treating the annual filing as a routine HR task will need to update their process. Company secretaries and boards need to be looped in well before the Board Report deadline.
Penalties for Non-Filing or Late Submission
Section 26 of the POSH Act sets the penalty for non-compliance at up to ₹50,000 for a first offence. This covers failure to file the annual report, failure to constitute an IC, and any other contravention of the Act’s provisions.
Repeat violations double the financial penalty and can result in cancellation or non-renewal of the business licence. For companies subject to the MCA 2025 amendment, a missing Board Report disclosure creates a separate layer of liability under the Companies Act. Both consequences can run simultaneously.
POSH Annual Return Checklist
Run through this before submitting:
- IC constituted correctly, including a minimum of four members, a majority of women, and one external member
- Report compiled in the posh annual report format prescribed under Rule 14
- NIL report prepared if no complaints were received
- Complaint data verified: received, disposed, pending beyond 90 days
- Awareness programme records available for reference
- IC member appointment letters in order
- IC registered on SHe-Box 2.0 (mandatory from 2025)
- Submission deadline confirmed with the relevant District Officer
- Board Report disclosure prepared if covered by the MCA 2025 amendment
Frequently Asked Questions
- Is filing mandatory even if there were no complaints?
Yes, a NIL report is still required. Zero complaints during the year does not exempt an organisation from filing. The report must confirm this explicitly and verify that the IC is properly constituted. - What is the filing deadline?
No single national date applies. Most districts use 31 January; Gurugram uses 28 February. The date is set by your District Officer, so check the current notification rather than assuming last year’s deadline holds. - Who signs the annual report?
The Presiding Officer of the IC signs it. The employer then forwards it to the District Officer. Under the MCA 2025 amendment, POSH disclosures in the Board Report are signed by the board of directors. - Do we file separately for each office location?
If offices are in different districts, yes, each files with its own District Officer. Multiple offices within the same district can usually be covered under one filing. When in doubt, check with the relevant DO. - What happens if we miss the deadline? Late or missing filings are non-compliance under Section 26: up to ₹50,000 for a first offence, doubled on repeat violations, with licence cancellation possible. The MCA Board Report liability runs separately for covered companies.
- Is SHe-Box registration mandatory along with filing?
From 2025, yes. The IC must be registered on SHe-Box 2.0 before filing online. These are two separate steps: portal registration and the act