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POSH Annual Reporting: IC Report, Employer Report and Board Disclosures

Separate POSH calendar-year committee reporting, employer disclosures and company Board-report counts, with a reconciled example and exact rules.

Authors: Nikhil Gupta & Kajri SinghSources checked 21 October 2026

Three reports with different purposes

Do not treat the Internal Committee's annual report, the employer's disclosure and a company's Board's Report as one interchangeable filing. Start with the calendar or financial year shown on the actual report.

RequirementWho prepares it / where it goesContent and period
POSH Act section 21 and Central Rule 14IC or LC; submit to the employer and District OfficerPrepare for each calendar year. Include complaints received, complaints disposed, cases pending over 90 days, workshops/awareness programmes and nature of employer/DO action.
POSH Act section 22Employer; organisation annual report, or intimation to the District Officer where no such report is requiredNumber of cases filed, if any, and their disposal. This separate employer duty does not replace section 21.
Companies (Accounts) Rule 8(5)(x)Company Board, where Rule 8 appliesIC-constitution compliance statement plus complaints received, disposed and pending over 90 days. G.S.R.357(E), dated 30 May 2025, made the added counts effective 14 July 2025.

Company scope matters: Rule 8(6) excludes One Person Companies and small companies from Rule 8 and Rule 8A provides their abridged Board-report regime. Determine that reporting route; do not call every Rule 8 disclosure compulsory for every company. The POSH Act's employer and committee duties still need separate application.

No invented all-India filing date: section 21 refers to the prescribed time. Central Rule 14 specifies contents, not a universal 31 January deadline. Use the notified District/State submission direction for the workplace and keep its date and acknowledgement. The calendar-year committee report and company financial-year figures may legitimately differ.

Worked reconciliation: calendar year 2025

Assumed facts: two complaints were open on 1 January; three were received during 2025; four were disposed during 2025. One older case remains pending at 31 December and is over 90 days old. Two awareness sessions were held.

FieldResultHow to support it
Opening cases2Prior-year closing register
Received in 20253Date-stamped receipt register
Disposed in 20254Committee disposal/closure records, including opening cases
Closing cases12 + 3 − 4 = 1
Pending over 90 days1Case-level age as at 31 December, not total closing cases automatically
Awareness programmes2Attendance and session records

A complaint first received in February 2026 is outside this calendar-year report even though it falls within a company's year ending 31 March 2026. Prepare a date-filtered bridge to the financial-year disclosure; do not alter either population just to make totals match. “Disposed” describes closure in the committee records; it does not mean every allegation was proved.

Build a report that can be traced

  1. Freeze the period, reporting unit and opening population.
  2. Reconcile received/disposed dates and check aging individually.
  3. Record training counts and the nature of action without identifying complainants or witnesses in public reporting.
  4. Have the committee finalise its report and preserve authorised copies and submission evidence for both required recipients.
  5. Prepare the employer and applicable Board-report disclosures from the correct period; retain a confidential reconciliation explaining differences.
  6. Enter the corresponding annual-report information in SHe-Box under the current portal workflow. An upload does not itself prove every statutory recipient received the report.

Integrate the policy, IC appointment and training evidence described in the POSH compliance-folder guide; keep the case-level register restricted. For portal steps, use the SHe-Box administration guide.

Questions readers ask

Is a zero-complaint year a reason to skip the committee report?

Section 21 requires an annual report for each calendar year. Record zero complaints accurately and still report training and other Rule 14 information; do not invent cases or infer that zero complaints proves an effective system.

Can the Board report publish a case narrative?

Section 16 protects complaint and inquiry information. Use the required aggregate counts and compliance statement without identifying a complainant, respondent or witness; avoid details that indirectly identify people.

Exact primary sources

Source text checked on 21 October 2026. Examples on this page use assumed facts and do not describe a real complaint.