Comprehensive POSH check list issued by Haryana Government

Comprehensive POSH check list issued by Haryana Government

Blogs
January 12, 2026

Haryana Government • POSH Compliance Guidance

Comprehensive POSH Checklist Issued by Haryana Government

The Haryana Government has issued a comprehensive POSH Act compliance checklist, highlighting the activities an employer must undertake to ensure effective implementation of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

Reference noted in the guidance

Additional Deputy Commissioner’s D.O. No. 51 dated 23/12/2025 (Gurugram, Haryana), issued to Government Departments and also in the capacity of District Officer under the POSH Act, 2013, outlines key compliance checkpoints including annual report submission.

Who is covered

Employers with ten or more employees must constitute the Internal Complaints Committee (ICC) and comply with reporting and preventive measures.

Reporting expectation

Annual POSH compliance reporting is required, including “zero case” reporting where no complaints were received during the year.

Submission timelines

The stated deadline is 31.12.25; in several districts and states, extended timelines allow submission up to 31.01.26.

Legal basis and purpose

Sections 21 and 22 of the POSH Act, 2013: Dual layers of compliance

Section 21 mandates the Internal Complaints Committee to prepare and submit an Annual Report for each calendar year to the employer and the District Officer.

Section 22 obliges employers to include details of such reports and actions taken in the organizational annual report, or, in the absence of one, to directly notify the District Officer.

Why this matters

The dual-reporting mechanism supports transparency, accountability, and traceability of complaints and preventive actions. It enables government monitoring and strengthens workplace safety governance.

Mandatory registration and digital submission

She-Box Registration (Effective June 2025)

The She-Box portal, launched by the Government of India, is stated to have transitioned from a grievance redressal tool to a mandatory compliance submission platform. Employers are required to register and upload the Annual POSH Report digitally, supporting centralized tracking, uniform reporting, and real-time monitoring.

Penalties and risk exposure

Consequences of non-compliance (Section 26 of the POSH Act)

Failure to constitute an ICC, conduct inquiries, or file annual reports can lead to fines up to ₹50,000 for the first offence. Repeated violations may attract penalties up to ₹1,00,000 and may result in cancellation or revocation of business licence (as stated).

Breach of confidentiality by ICC members may lead to a fine of ₹5,000 and potential removal from the committee (as stated).

Misrepresentation in Board Reports or false statements post-July 2025 is stated to attract fines up to ₹5,00,000 and may trigger further liability under the Companies Act.

Beyond monetary penalties, organizations may face reputational risks, regulatory scrutiny, and potential civil exposure for neglecting workplace safety duties.

Haryana Government checklist

Points covered with brief explanation

1. Policies

a) Confirmation of an internal POSH policy for prohibition, prevention and redressal; reference number to be stated.
b) Whether sexual harassment is treated as misconduct under service rules or standing orders; reference number to be stated.
c) Confirmation that the ICC has been constituted.

2. Notices

Whether notices are displayed, the location of display, and attachment of a sample copy. Details of ICC members should be displayed at prominent places in Hindi, English and local language, with a sample notice attached.

3. Employee awareness and assistance

a) Reporting of awareness programs and trainings through the following formats, with dates:

i) Physical orientation programs
ii) Virtual orientation programs
iii) Instructor-led virtual sessions
iv) E-learning programs disseminated

b) Coverage of contractual and support staff (including security, attendants, labour, drivers, loaders, etc.).
c) Communication on employee rights.
d) System/process to assist an aggrieved employee in approaching the ICC.
e) Support provided to the aggrieved person for filing a criminal complaint at the police station (where applicable).

4. Internal Committee constitution and readiness

Confirmation of ICC constitution and, where offices or administrative units exist at different locations, constitution of ICCs at each location as required. Details in prescribed format, including orientation programs for ICC members and facilities provided for proceedings.

5. Committee recommendations

Whether interim measures and recommendations issued by the ICC are followed up and implemented within prescribed timelines.

6. Reports

Whether the ICC has forwarded the Annual Report with necessary details to prescribed authorities, listing pending and resolved cases and confirming compliance with ICC constitution requirements under the POSH Act.

7. Annual Report attachment requirements

Annual Report prepared by the ICC should be attached and include:

Number of sexual harassment complaints received during the year

Number of complaints disposed of during the year

Number of complaints pending for more than 90 days with reasons for delay

Number of workshops or awareness programs conducted

Nature of action taken by employer or District Officer

Karma Global support

Managing POSH compliance for your organization

POSH compliance is not limited to administrative paperwork. It requires valid constitution and functioning of the ICC (including an external expert member), accurate recording and timely handling of complaints, structured awareness and training programs, and robust documentation of ICC meetings and proceedings.

Karma Global supports organizations to remain aligned with the substantive requirements of POSH compliance, treating it as a high-governance, high-risk obligation when not implemented rigorously.

For assistance and information, write to marketing@karmamgmt.com

Comprehensive POSH check list issued by Haryana Government