POSH Act 2013: Internal Committee (ICC) Requirements Explained

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — the POSH Act — requires most Indian workplaces to set up a complaints mechanism and follow defined procedures. This guide focuses on the Internal Committee (ICC), the cornerstone of compliance.

Who must form an Internal Committee?

Every workplace with 10 or more employees must constitute an Internal Committee (often called the ICC or IC) at each office or branch where 10 or more are employed. Workplaces below that threshold are covered by a Local Committee at the district level.

How the Internal Committee must be composed

The committee must include:

• A Presiding Officer — a woman employed at a senior level.
• At least two members from among employees, preferably committed to the cause of women or with relevant experience.
• One external member from an NGO or association working on women's issues, or someone familiar with sexual-harassment issues.

At least half of the members must be women.

Core compliance obligations

1. Constitute the ICC and notify members at each qualifying location.
2. Display the penal consequences of sexual harassment and ICC details prominently at the workplace.
3. Adopt a POSH policy defining harassment, the complaint process, and timelines.
4. Conduct awareness programmes for employees and orientation for ICC members.
5. Handle complaints within the statutory timelines — inquiry generally completed within 90 days.
6. File an annual report with the District Officer.
7. Include POSH compliance in your directors' report where applicable.

Timelines that matter

• A complaint can be filed within 3 months of an incident (extendable in certain cases).
• The inquiry should be completed within 90 days.
• The employer must act on recommendations within 60 days of receiving the report.

Why it matters

Beyond the legal duty, non-compliance can lead to fines, cancellation of business licences on repeat offences, and significant reputational risk. A properly constituted, trained ICC is the single most important step.

This guide is general information, not legal advice. Refer to the POSH Act and rules for the precise requirements applicable to your organisation.