NCW Calls for Mandatory POSH Audits: Is Your Organisation Ready?

The National Commission for Women (“NCW”) has issued an advisory on 19 June 2026 recommending significant measures to strengthen the implementation of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("POSH Act").

The advisory sends a clear message: POSH compliance is no longer just about constituting an Internal Committee — it is about demonstrating that your compliance framework actually works.

What's New?

1. Mandatory Annual POSH Audits

One of the key recommendations is the introduction of annual POSH audits for organizations employing 10 or more employees. The proposed audits would assess:

• Whether the Internal Committee is properly constituted;

• Whether complaints are handled in accordance with the POSH Act;

• Employee awareness and training initiatives;

• Confidentiality safeguards;

• Workplace safety measures;

• Statutory disclosures and reporting; and

• Use of the Government's SHe-Box platform.

2. Greater Regulatory Oversight

The NCW has recommended:

• State-level POSH Monitoring Cells and compliance dashboards;

• District-level monitoring by designated authorities; and

• Periodic review of organizations’ compliance with the POSH Act.

3. A Functional Internal Committee

The advisory reiterates that simply constituting an Internal Committee is not enough. It recommends that every Internal Committee:

• Complies with the statutory composition requirements;

• Includes a trained external member; and

• Receives regular capacity-building and investigation training.

  
  

An effective Internal Committee is as important as a legally compliant one.

4. More Awareness, Greater Transparency

The NCW has also encouraged organizations to:

• Conduct regular POSH awareness sessions;

• Prominently display complaint mechanisms and Internal Committee details;

• File annual reports on time; and

• Promote the use of the Government's SHe-Box platform.

  
  

5. Stronger Protection Against Retaliation

Recognizing that fear of retaliation often discourages reporting, the advisory recommends safeguards to protect complainants, witnesses and Internal Committee members throughout the inquiry process.

What Should Employers Do?

Although the advisory is recommendatory, it signals the direction in which regulatory expectations are evolving. Employers should consider reviewing whether they have:

• A properly constituted and trained Internal Committee;

• Robust POSH policies and reporting mechanisms;

• Regular employee awareness programmes;

• Complete statutory records; and

• Periodic internal compliance reviews.

Organizations that strengthen these processes now will be better prepared if States adopt the NCW's recommendations.

The NCW's advisory marks a shift from paper compliance to effective compliance. Going forward, organizations may increasingly be expected to demonstrate not only that they have complied with the POSH Act, but that their compliance framework is active, transparent and capable of effectively addressing workplace sexual harassment.