The POSH annual report is the yearly statement the Internal Committee (or Local Committee) must prepare under Section 21 of the POSH Act and submit to the employer and the District Officer. It is prepared for each calendar year, and a year with no complaints still needs one, with zeros. The Internal Committee prepares it.

What the committee reports

Rule 14 of the POSH Rules lists five items: complaints received in the year, complaints disposed of, cases pending for more than ninety days, workshops or awareness programmes held, and the nature of action taken by the employer or District Officer. The Act leaves the form and timing to be prescribed, and the Rules give contents but no single national due date, so follow whatever your District Officer or state labour department has asked for. Section 16 bars publishing the contents of a complaint or the identities of parties and witnesses, so the report carries numbers only.

The employer’s own disclosure, and a calendar mismatch

Section 22 separately requires the employer to include the number of cases filed and their disposal in its own annual report, or, where no such report is required, to tell the District Officer. Companies have an extra layer. The Companies (Accounts) Second Amendment Rules, 2025, in force from 14 July 2025, add to the Board’s Report the number of sexual harassment complaints received and disposed of in the year and those pending beyond 90 days, along with a statement that the company complies with the Maternity Benefit Act, 1961. Secondary sources differ on which financial year’s report first carried this, so check with your company secretary rather than assuming.

The practical trap is dates. The committee report runs on the calendar year, while the Board’s Report runs on the financial year ending 31 March. A simple fix is to have the IC share counts every quarter, so the Board figures can be assembled without guessing. The maternity benefit statement usually needs input from the same HR team.

Failing to act under Section 22, or breaching the Act’s other provisions, is punishable by a fine of up to Rs 50,000 under Section 26. For a repeat offence the punishment can be doubled, and the licence or registration to carry on business can be cancelled, withdrawn or not renewed.

Frequently asked questions

Is a nil report really required?

Yes. Section 21 says the committee shall prepare the report each calendar year, with no exception for years without complaints.

Does the Board’s Report requirement apply to every employer?

No, it applies to companies. Other employers still follow Section 22 by giving the numbers to the District Officer.

What if we have no Internal Committee at all?

Then the gap is the first problem, because Section 26 penalises it directly. A Local Committee only steps in for workplaces with fewer than ten workers or complaints against the employer.

Put the filing on your HR and payroll compliance calendar so the report is ready well before audit season.