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India Mandates Board Level POSH Disclosures

India is tightening Sexual Harassment reporting rules amid growing compliance push.

HR Policy Global Perspective: Sexual harassment complaints in Indian workplaces have risen sharply in recent years, signalling both increased awareness and persistent underlying issues.  However, large numbers of unresolved cases and cultural barriers underline ongoing gaps in enforcement and workplace safety frameworks.

The Bigger Picture

In July 2025, India introduced new regulatory requirements to strengthen enforcement of the Prevention of Sexual Harassment (POSH) Act, 2013. Under the updated Companies (Accounts) Second Amendment Rules, companies must now include detailed disclosures in their annual Board Reports. These include the number of complaints received and resolved, pending cases exceeding 90 days, and workforce gender composition. Employers must also confirm compliance with the Maternity Benefit Act, 1961.

This marks a shift from earlier rules that only required companies to confirm the presence of an Internal Complaints Committee (ICC). In parallel, the Supreme Court has mandated all public institutions establish ICCs, with a nationwide compliance report due in 2025. 

Proposed legislative amendments may soon extend the complaint filing window from 3 months to one year and remove the mandatory conciliation clause, allowing more formal investigations.

Actions for Employers

  • These reforms are a clear signal to employers of India’s transition from procedural compliance to measurable accountability. 
  • Employers must ensure stronger oversight of workplace grievance mechanisms and the integration of POSH compliance into governance frameworks. 
  • Companies are urged to reassess their internal policies, ICC training, and reporting protocols to ensure full alignment with evolving legal and ethical standards.
  • Additionally, Employers should review their implementation of the Maternity Benefits Act to validate compliance. 

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Authors: Michelle Swinden

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