What is a POSH policy?

A POSH policy is the written document through which an employer sets out its commitment under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — what conduct is prohibited, who sits on the Internal Committee, how a complaint is made, how it will be inquired into, the timelines that apply, and the consequences of a finding. It is the document employees are pointed to when they ask how to raise a concern.

What should a POSH policy contain?

At minimum: a definition of sexual harassment consistent with the Act, the scope of "workplace" as it applies to your organisation, the composition and contact details of the Internal Committee, how a complaint can be made and to whom, the inquiry process and its timelines, confidentiality obligations, protection against retaliation, the consequences of a finding, and the annual reporting obligation.

Is POSH training mandatory in India?

The employer duties under the Act include organising awareness programmes for employees at regular intervals, and the Rules contemplate orientation and skill-building programmes for Internal Committee members. In practice both are treated as expected rather than optional, and the absence of records showing they took place is one of the more common gaps found on review.

How often should POSH awareness training be conducted?

The Act refers to awareness programmes at regular intervals rather than naming a frequency. Most organisations run a full session annually, add POSH to induction so new joiners are covered as they arrive, and refresh Internal Committee training whenever the membership changes.

Who needs to be trained under POSH?

All employees need awareness of the policy and the complaint mechanism, including remote and contract staff who fall within your definition of workplace. Internal Committee members need substantially more: procedure, evidence handling, natural justice and confidentiality, because they conduct the inquiry.

What happens if a POSH policy exists but nobody has been trained?

The policy on its own does not discharge the employer duties. Awareness programmes are a separate obligation, and a committee that has never been trained on inquiry procedure is where otherwise sound cases tend to fail — on process rather than on facts.

POSH Policy and Training Requirements

What the POSH Act requires of an employer

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 places the obligation on the employer, not on the complainant. In practice that means four things: constitute an Internal Committee by written order, have and publicise a policy, run awareness programmes at regular intervals, and give the Committee the facilities and support it needs to conduct an inquiry — then report annually.

This page covers the policy and the training. For the Act itself — full form, applicability thresholds, how the Internal Committee is composed, complaint timelines and penalties — see our POSH Act 2013 explainer.

What a POSH policy must contain

A policy that only states the organisation’s disapproval of harassment is not a POSH policy. The document has to be usable by someone who is deciding whether to come forward, which means it must answer their practical questions without them having to ask anyone.

A definition of sexual harassment consistent with the Act, with examples that make it concrete rather than abstract.
The scope of “workplace” as it applies to you — offices, client sites, transport provided by the employer, off-site events, and how you treat remote and hybrid work.
The Internal Committee: who sits on it, including the external member, and how to reach them. Names and contact details, not just a job title.
How to make a complaint — to whom, in what form, and what happens next.
The inquiry process and its timelines, so nobody has to guess how long they are waiting.
Confidentiality obligations, and who is bound by them.
Protection against retaliation for complainants and witnesses.
Consequences of a finding, and the treatment of a complaint found to be malicious.
The annual reporting obligation and who owns it internally.

Two practical points. A policy nobody can find is functionally absent, so where it lives matters as much as what it says. And if you operate from more than one location, the Committee details in the policy have to be right for each of them — the Act contemplates constitution across applicable offices and administrative units, and a single head-office committee named in a policy used everywhere is a common mismatch.

POSH training: what the Rules actually require

“POSH training” is used to describe two different obligations, and organisations frequently do one and assume they have done both.

Employee awareness programmes

The employer duties include organising awareness programmes for employees at regular intervals. The purpose is that people know the policy exists, understand what conduct it covers, and know how to raise a complaint without having to ask around first. Adding POSH to induction is what keeps new joiners covered between annual sessions.

Internal Committee capability

Separately, the Rules contemplate orientation and capacity-building for Committee members. This is a different subject entirely: inquiry procedure, handling evidence, the principles of natural justice, and confidentiality. It matters because a committee that has never been trained on procedure is where sound cases tend to come apart — not on the facts, but on how the inquiry was conducted.

Committee membership changes. When it does, the new member needs the training, and the policy and displayed notices need updating with their details. That refresh is one of the most commonly missed steps in the whole framework.

Why this matters beyond the penalties

Non-compliance carries fines and, on repetition, risk to licences and registrations. That is the part usually quoted, and it is the least interesting part.

It decides whether someone comes forward at all. A visible policy and a committee people can name is the difference between a complaint being raised internally and being raised somewhere you cannot resolve it.
It is what an inquiry is judged on. Process failures — no documented procedure, no trained committee, no confidentiality controls — are what turn a defensible outcome into a challengeable one.
It is increasingly diligenced. Investors, enterprise customers and acquirers ask for the POSH framework and the annual returns. “We have a policy” does not survive the follow-up question.
It is a signal to employees. A framework that is current and communicated says something about the organisation that a filed-and-forgotten document does not.

Where organisations most often fall short

The pattern is consistent, and it is rarely the absence of a policy. It is the distance between the document and the practice.

A committee constituted years ago, with members who have since left.
No external member, or one appointed on paper who has never participated.
A single committee where multiple locations require their own.
A policy that exists but is not findable, and notices that are not displayed.
Awareness sessions that happened but were never recorded, so they cannot be evidenced.
Committee members who have had awareness training but no inquiry training.
The annual report treated as a formality, or missed entirely.

Most of these are invisible from the inside, because the documents all exist. They become visible the moment somebody asks to see the evidence for each one.

Check where you actually stand

Our free POSH Compliance Health Check scores your readiness across five weighted areas — IC constitution, policy and awareness, committee training, inquiry readiness and annual reporting. Twenty-five questions, about five minutes, and the score appears immediately.

Answering “Not sure” is scored as zero and flagged separately, because a control nobody can evidence is not yet a control.

Take the POSH Health Check

Frequently asked questions

What is a POSH policy?: A POSH policy is the written document through which an employer sets out its commitment under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — what conduct is prohibited, who sits on the Internal Committee, how a complaint is made, how it will be inquired into, the timelines that apply, and the consequences of a finding. It is the document employees are pointed to when they ask how to raise a concern.
What should a POSH policy contain?: At minimum: a definition of sexual harassment consistent with the Act, the scope of "workplace" as it applies to your organisation, the composition and contact details of the Internal Committee, how a complaint can be made and to whom, the inquiry process and its timelines, confidentiality obligations, protection against retaliation, the consequences of a finding, and the annual reporting obligation.
What is POSH training?: Two distinct things that are often confused. Employee awareness programmes explain what the policy is, what constitutes harassment, and how to raise a complaint. Separately, the Rules contemplate orientation and capacity-building for Internal Committee members, who need to understand inquiry procedure, natural justice and confidentiality. Running the first does not satisfy the second.
Is POSH training mandatory in India?: The employer duties under the Act include organising awareness programmes for employees at regular intervals, and the Rules contemplate orientation and skill-building programmes for Internal Committee members. In practice both are treated as expected rather than optional, and the absence of records showing they took place is one of the more common gaps found on review.
How often should POSH awareness training be conducted?: The Act refers to awareness programmes at regular intervals rather than naming a frequency. Most organisations run a full session annually, add POSH to induction so new joiners are covered as they arrive, and refresh Internal Committee training whenever the membership changes.
Who needs to be trained under POSH?: All employees need awareness of the policy and the complaint mechanism, including remote and contract staff who fall within your definition of workplace. Internal Committee members need substantially more: procedure, evidence handling, natural justice and confidentiality, because they conduct the inquiry.
What happens if a POSH policy exists but nobody has been trained?: The policy on its own does not discharge the employer duties. Awareness programmes are a separate obligation, and a committee that has never been trained on inquiry procedure is where otherwise sound cases tend to fail — on process rather than on facts.

This guide is general information for Indian employers, not legal advice. The POSH Act and Rules should be read in full, and specific situations should be discussed with a qualified adviser.

POSH policy and training requirements for Indian employers