Implementing Workflow Changes for Timely SHe-Box Registrations and Preventing Role-Conflicts Between Nodal Officers and ICC Members

In June 2025, the Delhi Government mandated the compulsory registration of Internal Complaints Committees on the SHe-Box portal for all public and private organizations with more than ten employees. These entities must appoint a separate "nodal officer" (not part of the ICC), upload training records, and file annual PoSH compliance reports through the portal. This requirement increases accountability and visibility for HR and compliance teams, but it also necessitates seamless digital readiness and clear role distinction.

What internal workflow changes must HR implement to ensure timely SHe-Box registrations and data uploads?

How can firms prevent role-conflicts by clearly separating nodal officers from ICC members?

To ensure timely SHe-Box registrations and data uploads, HR teams need to implement several internal workflow changes:

1. Establish a dedicated team or individual responsible for SHe-Box registration and data uploads. This will ensure that there's a clear point of accountability for these tasks.
2. Develop a comprehensive timeline for all SHe-Box related activities, including registration, data upload, and report submission. This timeline should be communicated to all relevant parties.
3. Implement regular training sessions for the team responsible for SHe-Box tasks to ensure they are up-to-date with the latest requirements and procedures.
4. Incorporate SHe-Box tasks into existing HR and compliance workflows to ensure they are not overlooked or delayed.

To prevent role-conflicts between nodal officers and ICC members, firms can take the following steps:

1. Clearly define the roles and responsibilities of the nodal officer and the ICC members. This should be communicated to everyone in the organization to ensure there's no confusion.
2. Ensure that the nodal officer and ICC members are not involved in the same cases to prevent any potential conflicts of interest.
3. Regularly review and update the roles and responsibilities of the nodal officer and ICC members to ensure they remain distinct and separate.
4. Provide regular training to both the nodal officer and ICC members to reinforce their separate roles and responsibilities.