Quick answer: An Internal Committee (IC) is the body that receives and inquires into sexual harassment complaints at work under the POSH Act, 2013. Every employer must constitute one by a written order. It needs a woman Presiding Officer, at least two employee members and one external member, with at least half the members women.
What is an Internal Committee under the POSH Act?
The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 is Act number 14 of 2013, and India Code lists it under that title. Section 3 says no woman shall be subjected to sexual harassment at any workplace. The Internal Committee is the in-house forum the Act creates so that a woman who faces harassment has a defined place to complain and a defined process that follows.
The word “workplace” is wide. Section 2(o) covers private organisations carrying on commercial, professional or industrial activity, and also any place the employee visits during the course of employment. The Press Information Bureau (PIB) notes that “employee” includes regular, temporary, ad hoc and daily-wage workers, volunteers, trainees, contract workers, apprentices, consultants and unpaid interns.
Who must constitute an Internal Committee?
Section 4(1) is direct: every employer of a workplace shall, by an order in writing, constitute a committee. A PIB backgrounder of 12 February 2026 says workplaces with 10 or more employees must have an IC. Smaller workplaces fall under the Local Committee that the District Officer sets up. The same release says Local Committees also hear complaints against the employer.
A separate PIB release of 6 February 2026 records the Supreme Court’s directions in Aureliano Fernandes v. State of Goa. District officers are surveying whether organisations have constituted their committees, and details are being brought onto the SHe-Box portal, which the Ministry launched on 29 August 2024.
How is the Internal Committee composed?
Section 4(2) sets out who sits on the committee. Section 4(3) sets the term.
| Seat | Who it must be |
|---|---|
| Presiding Officer | A woman employed at a senior level at the workplace |
| Employee members | Not less than 2 members from among employees, preferably committed to the cause of women |
| External member | 1 member from non-governmental organisations or associations committed to the cause of women |
| Gender balance | At least one-half of all members must be women |
| Term | Not more than 3 years, as the employer specifies |
The minimum is therefore four people: the Presiding Officer, two employee members and the external member.
Why does the external member matter?
The external member brings someone who is not on the company payroll into every inquiry. That protects the process in two ways. The complainant is less likely to feel that the outcome was decided by her own management, and the respondent can see that the inquiry was not run by his. Manas Center offers an annual POSH compliance service that includes an external member for the committee; the details are on the POSH page.
What else must an employer put in place?
Section 19 lists the employer’s duties. The text we checked does not use the word “policy”, but the duties it does list are easiest to meet with a written policy and a short checklist.
- Provide a safe working environment at the workplace.
- Display the penal consequences of sexual harassment and the order constituting the committee in a conspicuous place.
- Organise workshops and awareness programmes at regular intervals, and orientation for committee members.
- Treat sexual harassment as misconduct under service rules and start action against it.
- Keep the committee’s details current. Onboarding to SHe-Box is part of how the Ministry now tracks this.
A policy that names the committee, explains how to complain, states the timelines and promises confidentiality gives employees one document to read and gives HR one document to follow. The employer compliance checklist places POSH next to the other headcount-based duties.
What are the complaint and inquiry timelines?
| Step | Time limit | Section |
|---|---|---|
| Complaint filed | Within 3 months of the incident, or of the last incident in a series | 9(1) |
| Extension for good reason | Up to 3 more months, with reasons recorded in writing | 9(1) |
| Inquiry completed | Within 90 days | 11(4) |
| Report to employer | Within 10 days of completing the inquiry | 13(1) |
| Employer acts on recommendation | Within 60 days | 13(4) |
The committee follows the respondent’s service rules for inquiry where they exist. If harassment is proved, it can recommend action for misconduct and a payment to the aggrieved woman.
What is the annual report and what is the penalty?
Under Section 21, the committee prepares an annual report each calendar year in the prescribed form and sends it to the employer and the District Officer. Under Section 22, the employer includes the number of cases filed and how they were disposed of in its own annual report. If no such report is required, the employer informs the District Officer instead. PIB adds that the District Officer then sends a brief consolidated report to the State Government.
Under Section 26, failing to constitute a committee, or to act as Sections 13, 14 and 22 require, carries a fine of up to Rs. 50,000. PIB states that repeat violations bring double the fine and may lead to licence cancellation or non-renewal.
Frequently asked questions
No. The Press Information Bureau notes that Local Committees, set up by District Officers, handle complaints from workplaces with fewer than 10 employees and complaints against the employer. Such a small employer should still know the Local Committee route and tell staff about it.
Section 4(2)(a) says the Presiding Officer must be a woman employed at a senior level at the workplace. The employer names her in the written order that constitutes the committee, along with the other members.
The Presiding Officer and members hold office for a period specified by the employer, not exceeding three years from the date of nomination, as Section 4(3) sets out. The employer records the term in the constitution order and renews it on time.
In the Act text checked for this article, Section 19 lists duties such as displaying the committee order and penal consequences and holding awareness programmes. It does not use the word policy. A written policy is still the practical way to meet those duties.
Section 26 provides a fine of up to Rs. 50,000 for contravening provisions such as constituting the committee. The Press Information Bureau adds that repeat violations can bring double the fine and may affect licence renewal.
No. Manas Center is not a law firm and does not give legal advice. It offers an annual POSH compliance service, including an external member for the committee. Questions about your own legal position should go to a qualified lawyer.
Need help setting up your committee?
If you are not sure whether your committee meets Section 4, start with the POSH page, which includes a free committee check. To discuss your workplace, contact Manas Center. This article is general information, not legal advice.
Sources
- India Code: The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013
- Text of the Act, Sections 2, 3, 4, 6, 9, 11, 13, 19, 21, 22 and 26 (Indian Kanoon)
- PIB, 12 February 2026: SH Act and SHe-Box backgrounder
- PIB, 6 February 2026: Ministry of Women and Child Development release
Plain-language guides to POSH compliance for Indian employers, based on the Act, the Rules and court rulings. POSH compliance at Manas Center is led by Dr. Priya Dubey Sharma, Founder & Consulting Psychologist, as External Member.
