Documentation
We draft your POSH policy and the documentation needed to constitute a compliant Internal Committee, including sourcing guidance for the mandatory external member, so a company crossing the 10-employee threshold has a valid, fileable IC on record.
A POSH policy and the documentation needed to constitute a compliant Internal Committee, including sourcing guidance for the mandatory external member, so a company crossing the 10-employee threshold has a valid, fileable IC on record.
The POSH Act, 2013 requires any employer with 10 or more employees to constitute an Internal Committee (IC) at every office. The headcount includes everyone: permanent staff, interns, consultants, and daily-wage workers, well beyond people on formal payroll. It's a standing body that carries an annual reporting obligation, the kind of thing you can't just write up once and file away.
Most early-stage teams cross the 10-employee line before they have a dedicated HR function, which is exactly why the external member requirement, the piece we see missed most often, tends to get skipped.
Scope
Drafted for your organization: your headcount, your proposed committee members, your company details, rather than a generic policy download.
Section 4 of the POSH Act, 2013 sets the composition: a Presiding Officer who is a senior woman employee, at least two employee members, and one external member from an NGO or association working on women's issues, or otherwise familiar with sexual harassment matters. At least half the committee has to be women, each member serves a three-year term, and the external member is a mandatory seat.
We point you toward where to find an eligible external member rather than leaving that step to you unassisted.
We link the annual-return obligation to BuildWright's existing compliance-calendar tracking, rather than building a second, separate deadline system.
Specifics
Section 4 of the POSH Act sets the trigger at 10 or more employees at any office or administrative unit. The count includes contract workers, interns, consultants, and daily-wage or ad hoc staff, well beyond whoever appears on formal payroll. A team of six full-time employees and five contractors has already crossed the line.
An Internal Committee without an external member isn't validly constituted, full stop, whatever else is in place. The external member has to come from an NGO or association committed to women's causes, or otherwise be familiar with sexual harassment issues. Companies routinely build a committee of internal staff only and call it done. We treat sourcing this member as part of the deliverable rather than something we leave to you.
The IC has to prepare and submit an annual report to the District Officer each calendar year: complaints received, complaints disposed, complaints pending, and actions taken. That repeats every year rather than closing out once the committee is set up, which is why we tie the reminder to your existing compliance calendar instead of a standalone tracker.
Section 26 sets a penalty of up to ₹50,000 for a first offence of not constituting a valid IC. A repeat offence carries a doubled penalty, and some sources note exposure to business licence cancellation on repeat non-compliance.
Process
Step 1 of 4
Confirm your headcount
Including contractors, interns, and daily-wage staff, to confirm you're actually over the 10-employee threshold.
Common mistakes founders make
Clarifications
Yes. The POSH Act's 10-employee threshold counts everyone at the office, well beyond formal payroll. 11 people total means the obligation applies.
No. The external member is mandatory. Without one, the IC isn't validly constituted, regardless of how the rest of the committee is set up.
Section 26 sets a penalty of up to ₹50,000 for a first offence of not constituting a valid IC, doubled for a repeat offence.
No. The IC has an ongoing annual reporting obligation to the District Officer. We tie the reminder to your existing compliance calendar so it doesn't get missed.
Related
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Guides that walk through every step.
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