On 19 June 2026, the National Commission for Women issued a formal advisory addressed to Chief Secretaries and Directors General of Police of all States and Union Territories, with further dissemination to District Magistrates, SSPs, and Commissioners of Police across India. The advisory calls for immediate, comprehensive enforcement of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
The advisory does not amend or supplement the POSH Act. It is an enforcement and accountability directive issued by NCW as a press release.
The advisory contains 18 specific measures. The following are directly actionable by the establishments:
| # | NCW Advisory Measure | POSH Act Reference | Risk if Not Complied |
| 1 | Mandatory annual POSH audit for all establishments employing 10 or more persons | No express provision in the POSH Act — see Section 3 below | Treated as non-compliance per NCW Advisory; audit finding reportable to District Authority |
| 2 | IC must be constituted in every office, branch, and unit — not just HQ | Sec. 4(1) | Each uncovered unit is an independent violation; penalty up to ₹50,000 under Sec. 26 |
| 3 | IC must have a woman Presiding Officer, external expert, and minimum 50% women members | Sec. 4(2) | IC inquiries challengeable; relief orders may be set aside on procedural grounds |
| 4 | Annual reports to be mandatorily submitted and tracked by District Authority | Sec. 21 (IC report); Sec. 22 (employer annual report) | Non-submission is non-compliance under existing law; now actively auditable |
| 5 | IC/LC members must receive specialised training; regular awareness programmes for all employees | Sec. 19(b), (c), (g) | Absence of training records is an adverse finding in audit or litigation |
| 6 | IC details, complaint procedure, and contact information to be publicly displayed on website and premises | Sec. 19 (employer duties); Sec. 4 (IC details) | Absent disclosures can be cited as evidence of hostile intent in complaint proceedings |
| 7 | Complainants, witnesses, and IC members to be protected from retaliation, adverse transfers, or professional prejudice | Sec. 12 (interim relief); Sec. 17 (confidentiality) | Retaliation can escalate an IC matter to a criminal complaint under BNS; significant reputational risk |
| 8 | Active promotion and use of SHe-Box platform for online complaint registration and tracking | Sec. 19 (awareness obligation) | Promote awareness and encourage adoption of the SHe‑Box platform |
New: Mandatory Annual POSH Audit — Detailed Position
The advisory recommends mandatory annual POSH audits for all establishments employing ten or more persons. The audit must assess the following eight parameters:
- Legal compliance — IC constitution, composition, and member terms
- Functioning of Internal Committees — processes, quorum, and inquiry conduct
- Status of complaints — pending, disposed, and timelines
- Confidentiality safeguards
- Workplace safety infrastructure
- Awareness initiatives
- Mandatory disclosures
- Utilisation of the SHe-Box platform
Audit reports are to be submitted to District Authorities and concerned departments. Non-conduct of the audit is itself treated as non-compliance.
Legal Gaps in the Audit Requirement
First — this audit has no statutory basis in the POSH Act itself.
Second — “District Authorities” as recipients of audit reports is undefined under the POSH Act.
Third — no prescribed format, frequency methodology, or auditor qualification exists yet.
This advisory has been issued as a press release by the National Commission for Women (NCW). It is not a formal notification or circular from the Ministry of Labour & Employment or under the POSH Act, 2013.
We recommend that you consult your legal counsel on the enforceability of the audit submission requirement before submitting any report to District Authorities.