What changed
The 2025 amendments tightened three areas: ICC composition (now requires an external member who has at least five years of experience in gender-issues work), training cadence (annual mandatory for ICC members, biennial for all employees), and reporting (annual report to the District Officer, not just internal).
Companies with under ten employees are still exempt from the ICC requirement but must designate a Local Complaints Committee contact. Most fast-growth companies cross the threshold without realising and run for months out of compliance.
The action checklist
Five concrete actions: confirm ICC composition matches the new requirements, document the annual training delivery, file the annual report by the due date for your state, refresh the policy document with the amended language, and surface the policy at onboarding (we ship it in Core HR onboarding flows).
The policy refresh is the easiest one to defer and the worst to defer. Out-of-date policy language can invalidate a complaint outcome.
The training cadence
Annual training for ICC members is non-negotiable. The training must be substantive (case-based, role-played complaints, deliberation rubrics), not a video and a quiz. Most ICC members we speak to have been to one good training session ever; the rest were checkbox exercises.
Pair this with the broader compliance posture in our DPDP coverage; the same operational discipline applies.