Internal Committee formation under POSH Act s.4
We constitute compliant Internal Committees for organisations with 10 or more employees — drafting the written appointment order, sourcing the external member required under s.4(2)(c), and preparing the policy and notices that make the IC valid from the day it is signed, not just on paper. Work runs onsite across Delhi NCR and online pan-India.
Does this apply to us?
10 or more employees
This is the trigger — an organisation crossing 10 or more employees (s.4) must constitute an Internal Committee.
Multiple branch offices
Each office, branch or administrative unit constitutes its own IC under s.4 — a single head-office IC does not cover other locations.
Fewer than 10 employees
No Internal Committee is legally required. Complaints instead go to the Local Committee constituted at the district level. We still recommend constituting an IC for any mixed-gender team, even below the 10-employee threshold.
Contractors, interns, remote/WFH staff
These categories are protected complainants under the Act, and count toward the 10-employee threshold — including interns and remote/WFH staff.
What we deliver
- IC composition drafted to spec: a Presiding Officer (a senior woman employee), at least two employee members, one external member under s.4(2)(c), with at least half the total membership women.
- A written appointment order — verbal or informal arrangements do not constitute valid IC constitution.
- Term set at up to 3 years, tracked so reconstitution happens before it lapses.
- Per-branch ICs where the organisation has more than one office.
- The external member's signed confidentiality undertaking, executed before joining the IC.
- The s.19 notice of penal consequences, prepared for display at the workplace.
- POSH policy drafting, in English or Hindi — delivery format confirmed at scoping.
The statutory basis
| Provision | Requirement |
|---|---|
| s.4 | Threshold: 10 or more employees. |
| s.4 | Composition: Presiding Officer, 2+ employee members, 1 external member (s.4(2)(c)), at least half women; term up to 3 years. |
| s.4 | Appointment by written order; verbal or informal arrangements are invalid. |
| s.4 | Each office, branch or administrative unit constitutes its own IC. |
| s.19 | Awareness programmes/workshops at regular intervals; notice of penal consequences displayed at the workplace. |
| s.21, Rule 14 | Annual report prepared by the IC, submitted to the employer and the District Officer. |
| s.26(1) / s.26(2) | Penalty up to ₹50,000 for a first contravention; on repeat, government may cancel licence, registration or approval. |
| Companies Act 2013 | POSH compliance disclosure required in the Board's Report. |
Who delivers it
IC formation is led by our advocate panel, including the sourced external member. See the panel for names and enrolment numbers, and how to verify each entry at verification.
Price
IC formation is priced ₹10,000–50,000, one-time. See pricing for the current structure.
What we do not do
- We do not act as the Presiding Officer or an employee member — those seats must be filled internally under s.4.
- We do not backdate appointment orders or treat a verbal arrangement as sufficient.
- We do not guarantee District Officer or Local Committee processing timelines outside our control.
- We do not draft a policy without a corresponding written appointment order — the two are issued together.
Frequently asked
At what size are we required to constitute an Internal Committee?
At 10 or more employees, per s.4. Below that threshold, the Local Committee at the district level handles complaints instead.
Who must sit on the IC?
A Presiding Officer who is a senior woman employee, at least two employee members, and one external member under s.4(2)(c), with at least half the total membership women.
Is a verbally agreed IC valid?
No. Section 4 requires a written appointment order; verbal or informal arrangements do not constitute valid IC constitution.
Do our branch offices need separate ICs?
Yes — each office, branch or administrative unit constitutes its own IC under s.4.
How long does an IC's term run?
Up to three years, after which it must be reconstituted.
Does the external member sign anything before joining?
Yes, a confidentiality undertaking, executed before joining the IC.
Do we need to display anything at the workplace?
Yes — a notice of the penal consequences of sexual harassment, prepared as part of the s.19 obligations we deliver alongside formation.
What is the penalty for not constituting an IC?
Up to ₹50,000 for a first contravention under s.26(1); a repeat contravention can lead to cancellation of licence, registration or approval under s.26(2).
Do contractors and interns count toward our headcount?
They are protected complainants under the Act regardless. Whether they count toward the 10-employee threshold for your specific structure needs to be confirmed case by case.
Does forming the IC include a policy document?
Yes — we draft the POSH policy alongside the appointment order, in the format and language agreed for your organisation.
Where to go next
The composition arithmetic at the smallest size that clears the s.4 threshold.
Check this against the record
Everything on this page rests on the statute, the Rules, or a reported judgment. These are the originals — links open on the issuing body's own site.
The Government of India repository carrying the bare text of the POSH Act 2013 and its Rules.
The Supreme Court's directions on IC constitution and procedural compliance, 12 May 2023.