In August–September 2025, the Supreme Court directed labour authorities to complete a district-wise survey of PoSH compliance (constitution and functioning of Internal Committees, disclosures, reporting) within six weeks from 12 Aug 2025—a clear shift from passive filings to field verification. Multiple legal updates summarise the order and its timeline, and practitioner alerts warn that non-compliance could affect licences/registrations. Meanwhile, states have added fuel: Rajasthan and Delhi (NCT) have separately pushed mandatory SHe-Box registration and IC detail uploads shortly after notification—tightening traceability of compliance.
cecureus.com
For HR/compliance, this means treating PoSH like a statutory controls audit: (1) re-constitute/notify ICs with quorum and external member proof; (2) publish IC contacts internally and on the intranet; (3) schedule and evidence annual awareness/training; (4) file annual reports with district authorities; and (5) if in Rajasthan/Delhi, register on SHe-Box and upload IC details within the prescribed window. Expect site-level checks and requests for minutes, inquiry reports (anonymised), and evidence of action taken. Several social posts have circulated a later “upload by mid-October” narrative—use the Supreme Court order date as your anchor and verify state-specific timelines locally.
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Sources:
• SC directs district-wise PoSH compliance survey; six-week deadline from 12 Aug 2025 — SCC Online — 19 Aug 2025.
SCC Online
• Supreme Court mandates six-week compliance survey for PoSH Act — DLA Piper update — 27 Aug 2025.
DLA Piper GENIE
• Sexual harassment law compliance under the spotlight — JSA (Lexology) — 17 Sep 2025.
Lexology
• Rajasthan mandates SHe-Box registration — Legality Simplified — 23 Jun 2025; Delhi SHe-Box notice & FAQs — CecureUS explainer — 25 Jul 2025.
Legality Simplified
Discussion questions:
What proof (artifacts) can you produce today to show your IC is valid and functioning?
How will you track SHe-Box registrations and filings across all Indian entities/sites?
Which gaps in training/documentation would an inspector find in your last 12 months of PoSH activity?
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5cecureus.com
For HR/compliance, this means treating PoSH like a statutory controls audit: (1) re-constitute/notify ICs with quorum and external member proof; (2) publish IC contacts internally and on the intranet; (3) schedule and evidence annual awareness/training; (4) file annual reports with district authorities; and (5) if in Rajasthan/Delhi, register on SHe-Box and upload IC details within the prescribed window. Expect site-level checks and requests for minutes, inquiry reports (anonymised), and evidence of action taken. Several social posts have circulated a later “upload by mid-October” narrative—use the Supreme Court order date as your anchor and verify state-specific timelines locally.
Sources:
• SC directs district-wise PoSH compliance survey; six-week deadline from 12 Aug 2025 — SCC Online — 19 Aug 2025.
SCC Online
• Supreme Court mandates six-week compliance survey for PoSH Act — DLA Piper update — 27 Aug 2025.
DLA Piper GENIE
• Sexual harassment law compliance under the spotlight — JSA (Lexology) — 17 Sep 2025.
Lexology
• Rajasthan mandates SHe-Box registration — Legality Simplified — 23 Jun 2025; Delhi SHe-Box notice & FAQs — CecureUS explainer — 25 Jul 2025.
Legality Simplified
Discussion questions:
What proof (artifacts) can you produce today to show your IC is valid and functioning?
How will you track SHe-Box registrations and filings across all Indian entities/sites?
Which gaps in training/documentation would an inspector find in your last 12 months of PoSH activity?
Acknowledge(0)Amend(0)
To demonstrate that your Internal Committee (IC) is valid and functioning, you can produce the following artifacts:
1. Proof of IC constitution, including the appointment letters of the members.
2. Minutes of the IC meetings held, which shows the quorum was met.
3. Any reports or recommendations made by the IC.
4. Evidence of any action taken based on the IC's recommendations.
To track SHe-Box registrations and filings across all Indian entities/sites, you can:
1. Maintain a centralized database of all registrations and filings.
2. Assign a dedicated team or individual to monitor and update the database regularly.
3. Use a compliance management software to automate the tracking process.
To identify potential gaps in training/documentation that an inspector might find in your last 12 months of PoSH activity, you should:
1. Review your training records to ensure all employees have received the required training.
2. Check that all training sessions have been properly documented, including attendee lists, training materials used, and post-training evaluations.
3. Ensure that all incidents of sexual harassment have been properly reported and documented, and that appropriate action has been taken in each case.
4. Regularly audit your PoSH compliance to identify and address any gaps proactively.
From India, Gurugram
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1. Proof of IC constitution, including the appointment letters of the members.
2. Minutes of the IC meetings held, which shows the quorum was met.
3. Any reports or recommendations made by the IC.
4. Evidence of any action taken based on the IC's recommendations.
To track SHe-Box registrations and filings across all Indian entities/sites, you can:
1. Maintain a centralized database of all registrations and filings.
2. Assign a dedicated team or individual to monitor and update the database regularly.
3. Use a compliance management software to automate the tracking process.
To identify potential gaps in training/documentation that an inspector might find in your last 12 months of PoSH activity, you should:
1. Review your training records to ensure all employees have received the required training.
2. Check that all training sessions have been properly documented, including attendee lists, training materials used, and post-training evaluations.
3. Ensure that all incidents of sexual harassment have been properly reported and documented, and that appropriate action has been taken in each case.
4. Regularly audit your PoSH compliance to identify and address any gaps proactively.
From India, Gurugram
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