POSH Act 2013 · For MSMEs, factories and small businesses

POSH compliance for MSMEs and factories

Paying EPF or ESIC? If 10 or more people work at a workplace, the POSH Act applies too. It is the one most small firms miss. We set it up for you, with a psychologist as your external member.

From ₹22,499 a year for up to 30 employees · one account for all your units · prices exclusive of GST

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The headcount test

EPF, ESIC and POSH: three different counts

Owners usually know when EPF and ESIC start. POSH starts at a similar size, but it counts people differently.

Headcount triggers for three employer duties. Each law has its own definition of who counts.
EPF	Establishments with 20 or more employees.Source: Code on Social Security, 2020 (PIB factsheet) ↗
ESIC	Establishments with 10 or more employees. Voluntary below 10. Mandatory even for one worker in hazardous work.Source: Code on Social Security, 2020 (PIB factsheet) ↗
POSH	Every workplace with 10 or more employees must set up an Internal Committee. “Employee” includes contract workers, probationers, trainees and apprentices, paid or unpaid, hired directly or through a contractor.Source: POSH Act, Sections 2(f) and 4 ↗

The rule of thumb: if you pay ESIC because you have 10 or more people, check POSH the same day. If you pay EPF, you have at least 20 people, so POSH almost certainly applies to that workplace. The counts are not identical (ESIC can be voluntary; POSH counts per workplace and includes unpaid trainees), so count carefully.

What is different in a factory or small firm

What does POSH look like on the shop floor?

Headcount

Contract labor counts

Workers supplied by a contractor are “employees” under the Act, even if they are not on your payroll. They count toward the 10, and they can complain to your committee.

Multiple units

A committee at each unit

Where your offices or units are at different places, the Act asks for an Internal Committee at each of them. Our plan covers all your units in one account, priced by total headcount.

Day to day

Shifts, visitors and vendors

Harassment by a visitor, vendor or customer at your workplace is covered too. Each unit gets its own complaint link and QR code, so a worker on any shift can complain privately.

Language

Hindi, not just English

Your workers can complain in Hindi on our form, check their case status in Hindi, and read a bilingual display notice on the wall.

Small units

Under 10 people?

You do not need your own committee, but complaints then go to the district’s Local Committee, and the employer duties in Section 19 still apply.

Who is covered

Any legal form

Proprietorships, partnerships, LLPs and companies are all covered. Companies that are not “small companies” must also report POSH in the Board’s Report.

Source: POSH Act, Sections 2(f), 4, 6 and 19 ↗ · Companies Act s.134(8) ↗

What you get

What does a small firm need? One plan.

Dr. Priya Dubey Sharma as the external member on your Internal Committee, for every unit. She takes part in every inquiry.
Your POSH policy, committee order and appointment letters, drafted for your company.
A complaint link and QR code for each unit, 10 awareness posters in English and Hindi and a Hindi and English display notice.
A private portal for your committee, with the legal deadlines on every case.
Your Section 21 annual report, made from your records, and step-by-step SHe-Box help.
Optional awareness training for workers and supervisors, online (₹6,999 per session) or at your unit (₹15,000 per day).

See all plans and prices · Up to 30 employees: ₹22,499 a year · 31–100: ₹26,999

Included in every plan

What proof can you show a buyer?

Large customers and auditors now ask MSME suppliers for POSH proof. These come with the plan at no extra cost.

Verification

A compliance badge anyone can check

Publish a Manas badge on your website and a printable QR version for your office. It links to a live page that shows whether your status is current today, so buyers and auditors can check it themselves. It is a record from Manas, not a government certificate.

Records

Certificate and audit pack

A dated compliance-status certificate and an audit-ready pack for each office: committee roster, checklist, complaint-log summary and an index of every document, for vendor audits and due diligence.

Deadlines

A compliance calendar that reminds you

Annual report due dates, committee tenure and training are tracked for you, with email reminders before each deadline, and a log of your quarterly committee meetings.

For the complainant

A tracking code for every complaint

Each complaint gets a tracking code, so the person who complained can check the status online, in English or Hindi, without asking anyone at work.

Filings

Board’s Report text for your CA

A private company that is not a small company must report POSH complaints, employee headcount by gender and Maternity Benefit Act compliance in its Board’s Report. The portal drafts that paragraph from your records, ready for your CA or CS to paste.

Low risk

14-day money-back

Change your mind within 14 days of paying for the annual plan and we refund the plan fee in full, as long as no signed documents have been issued yet. Refund policy.

We are an MSME too

Small-business people, serving small businesses

Manas Center for Mental Wellness and Counselling is a Udyam-registered MSME (UDYAM-MP-10-0120839).

Manu Anirudh Sharma, Co-Founder & CEO of Manas, and Manas 365 Mindtech Private Limited are members of Laghu Udyog Bharati, Bhopal unit.

Questions from MSME owners

What do small firms ask about POSH?

Is POSH compliance mandatory for MSMEs?

Yes. The POSH Act has no MSME exemption. Every workplace with 10 or more employees must set up an Internal Committee with an external member (Section 4), and every employer has the duties in Section 19, such as a policy, awareness sessions and displaying the penalties. Udyam registration does not change this. Source: POSH Act ↗.

We are registered for ESIC. Does POSH apply to us?

Very likely. ESIC generally starts at 10 employees, the same number as POSH. But the counts differ: ESIC can be voluntary below 10, and POSH counts each workplace and includes unpaid trainees and apprentices. If 10 or more people work at a unit, that unit needs an Internal Committee.

Do contract workers count toward the 10?

Yes. The Act’s definition of “employee” includes people working through a contractor, with or without the principal employer’s knowledge, and contract workers, probationers, trainees and apprentices. Source: Section 2(f) ↗.

We have two factories. Do we need two committees?

The Act asks for an Internal Committee at each administrative unit or office located at different places. Our plan covers all your units in one account, priced by your total headcount, and Dr. Priya is the external member for each committee.

We have fewer than 10 employees. What applies?

You do not need your own Internal Committee. A complaint from your workplace goes to the district’s Local Committee. You still have the general employer duties under Section 19, so a simple policy and awareness are still wise.

How much does it cost for a small factory?

₹22,499 a year for up to 30 employees, or ₹26,999 for 31 to 100, including the external member, documents, portal and annual report. Prices are exclusive of GST. Training is optional.

Last updated: 26 September 2026 · General information, not legal advice. Manas is not a law firm and works alongside your legal counsel.

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Set up POSH for every unit