Section 21 of the PoSH Act requires every Internal Complaints Committee to file an annual report. This toolkit walks you through exactly what to prepare, what to include, and when to file.
The annual report under Section 21 of the PoSH Act is a mandatory document that every Internal Complaints Committee (IC) must prepare at the end of each calendar year. It is not optional, and it is not the same as your company's annual report — it is a separate compliance filing.
The report must be submitted by the IC to two recipients independently: the employer (for inclusion in the company's broader annual filing) and the District Officer of the relevant district. Failure to file with either recipient is a violation.
The report covers the period January 1 to December 31 of the preceding year and must be submitted before January 31. If your organisation has ICs at multiple locations, each IC files its own annual report independently.
Section 21(1): "The Internal Committee... shall in each calendar year prepare, in such form and at such time as may be prescribed, an annual report and submit the same to the employer and the District Officer."
Section 22 further requires the employer to include the number of cases filed under the Act and their disposal in any report prepared under any other applicable law — including the Companies Act for listed companies. This means your PoSH data flows into your corporate disclosures.
Submit before January 31 each year for the prior calendar year
Employer and District Officer receive independent copies
Each branch IC files its own report; no consolidated filing
Calendar year (January 1 to December 31)
The Rules under the PoSH Act prescribe six specific data points that must appear in every annual report. Missing any one of them makes the report incomplete.
The total count of written complaints formally received by the IC during the calendar year — including complaints received from third-party or contract workers.
The number of complaints on which the IC completed its inquiry and submitted its recommendations to the employer — whether or not the employer has yet acted on them.
Complaints received where the IC inquiry was initiated but not concluded as of December 31 of the reporting year. The reason for pendency should be documented.
A description of the disciplinary or remedial action taken by the employer on IC recommendations — warnings, transfers, suspensions, terminations, or compensation orders.
The number of cases where the employer directed the complainant to file a police complaint under the IPC for conduct that also constituted a specific criminal offence.
The number of training sessions, workshops, seminars, or awareness programmes conducted for employees and IC members during the year, with approximate attendee counts.
Run through this checklist every December to ensure your annual report is accurate, complete, and ready to file before the January 31 deadline.
All IC meetings held during the year are documented with signed minutes. Minutes must be retained for future audits.
Maintain a formal complaint register — even if the entry is "zero complaints received." A blank register is still a required document.
All completed inquiry files are finalised, signed, and stored securely. Each file should include the complaint, inquiry record, IC report, and employer action taken.
Any cases still under inquiry are noted with the reason for pendency and the current stage of proceedings.
Attendance records, session materials, and dates for every awareness programme or training session conducted during the year.
Confirm the total number of employees at the workplace, including contract workers and third-party employees who may be covered by the policy.
For each complaint disposed of, verify that the employer's response to the IC's recommendations is documented in writing.
Verify that no IC member's term has expired. Check whether reconstitution is needed before filing to ensure the IC is valid.
The External IC Member was available for and participated in all inquiry proceedings during the year. Their fees (if any) are settled.
The annual report document is drafted in the prescribed form and reviewed by the Presiding Officer and at least one other IC member before submission.
A signed copy of the report addressed to the designated employer/HR authority is ready for submission with proof of receipt.
A separate signed copy addressed to the District Officer (typically the District Collector or their authorised officer) is prepared for independent submission.
We don't just remind you to file. We prepare the report, compile your data, and submit it on your behalf — before the deadline.
POSH360's compliance engine tracks your complaints, inquiry timelines, training sessions, and IC activity throughout the year. By December, your annual report data is already compiled — no scrambling through emails and folders.
We draft the annual report in the form prescribed under the PoSH (Central) Rules, 2013. The draft is sent to your Presiding Officer for review and sign-off before we submit. You always have visibility and control.
Once approved, we file the report on your behalf with the employer authority and the relevant District Officer — before January 31. You receive a filing confirmation with delivery proof for your records.
Mark these dates in your compliance calendar. Missing any of them creates cumulative risk that is difficult to remediate after the fact.
| Period | Compliance Task | Details |
|---|---|---|
| January | Annual Report FilingCritical | Submit annual report for prior year to employer and District Officer. Deadline is January 31. Reports for previous calendar year (January 1 to December 31). |
| February – March | IC Review Meeting | Conduct the first IC meeting of the year. Review and update internal processes, complaint intake mechanism, and IC member availability for the year ahead. |
| April – June | Employee Awareness Training | Conduct annual PoSH awareness training for all employees. Training must be documented with attendance records, session materials, and trainer credentials. |
| July | IC Member Orientation | Conduct orientation or refresher training for IC members. External Member should participate. Document attendance and topics covered. |
| October | IC Term Expiry Check | Check whether any IC member's term expires before December 31. Initiate reconstitution proceedings early to avoid a compliance gap at year-end. |
| November – December | Annual Report Data CompilationDeadline Prep | Compile complaint register, training logs, IC minutes, and employer action records for the full calendar year. Ensure all pending cases have documented status updates. |
| December | Policy and IC Annual Review | Review the PoSH policy for any required updates — legislative changes, organisational restructuring, new office locations. Update and re-circulate if amended. |
We compile your data, draft the report, and submit it to both recipients before January 31. You sign off and move on.
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