Five-step checklist for ICC composition, training cadence, annual report filing, policy refresh, and onboarding integration after the 2025 amendments.
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The 2025 amendments tightened three areas: ICC composition (now requires an external member with 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.
Walk through the five items annually with the ICC chair. Each item has a date-stamp slot and an owner; complete and archive at the end of each cycle.
The training cadence is the easiest to defer and the worst to defer. Out-of-date training can invalidate a complaint outcome.
Surface the POSH policy at onboarding, not buried in a handbook PDF that nobody reads. pPULSE Core HR onboarding flows ship with the policy as a first-day item.
First-month POSH literacy correlates with healthier reporting culture; companies that make this a day-one read see better incident-resolution outcomes.
Ten employees or more, per the act. Companies under the threshold can either designate an external complaints committee contact or constitute an ICC voluntarily.
Per the 2025 amendments, an external member must have at least five years of experience in gender-issues work. Lawyers, NGO representatives, or academics in gender studies typically qualify.
Within the first quarter of the financial year, with the District Officer of the jurisdiction where the head office is registered. State-specific timelines vary slightly; check your local notification.
POSH is one of several India-specific HR compliance areas. See our POSH amendments brief and pair this with the DPDP readiness checklist for full coverage.
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