Understand your organisation’s POSH responsibilities and what to review next. Examine policy, committee arrangements, employee awareness, complaint processes and reporting, while distinguishing applicable legal requirements from recommended governance practices.
Use these seven areas to guide an organisational review. Each identifies arrangements or records to examine; the examples are review prompts, not a complete list of statutory requirements. Distinguish duties under the Act and Rules from recommended controls, and seek legal advice on fact-specific questions.
01
Area 01 · Applicability
Scope and organisational context
Map your workplaces, establishments, workforce and locations using an organisation chart and location list. Check where an Internal Committee is required, when the Local Committee route applies, and how complaints against the employer are routed. Resolve uncertain applicability through fact-specific legal review.
02
Area 02 · Policy & Prevention
Policy, communication and workplace displays
Examine the current policy, reporting contacts, communication materials and required workplace displays. Check how employees access this information. Distinguish statutory and Rules-based duties from recommended controls such as acknowledgements and accessible language versions.
03
Area 03 · Committee Governance
Internal Committee and Local Committee readiness
Examine the constitution order, appointment records, membership and tenure of the Internal Committee where required. Check role clarity and identify the Local Committee route where relevant. Detailed composition and multi-location arrangements require legal review; continuity planning is a recommended control.
04
Area 04 · Awareness
Awareness and role readiness
Review employee awareness and Internal Committee orientation records alongside the content delivered. Can employees identify reporting routes, and do managers, HR and leaders understand their response boundaries? Use coverage records to identify learning needs. Training alone does not establish compliance.
Examine reporting instructions, inquiry-process guidance and record-access arrangements without circulating complaint details. Check how Section 16 confidentiality restrictions are handled in practice. Management support must preserve the Internal Committee’s independence and responsibility for its findings and recommendations.
06
Area 06 · Employer Duties
Operational employer responsibilities
Check how employer duties are assigned and carried out: a safe workplace, committee facilities, attendance and information assistance, applicable criminal-law support, service-rule processes and timely committee reporting. A responsibility map can help identify who provides support and how requests are handled.
07
Area 07 · Reporting & Records
Reporting, disclosures, records and review
Review committee and employer reporting separately, using reporting inputs, preparation records and submission acknowledgements where applicable. Verify current state-specific filing routes and deadlines against official sources. Check other disclosures only where applicable. Periodic internal review is a recommended control, not a universal annual statutory duty.
Statutory context
Read the Act provisions that shape the operating framework.
The POSH Act and applicable Rules set legal duties; the framework above also includes recommended governance controls. Check the source text and seek fact-specific advice where applicability is uncertain.
Use these questions to spot arrangements that need a closer look. An uncertain answer is a starting point for review, not a finding of breach.
For each uncertainty, record what needs checking, who can clarify it and the next action. Keep this organisational review separate from the facts or merits of any individual complaint.
Check 01
Have new locations or workforce changes been checked for their effect on POSH arrangements?
Check 02
Can employees find the current policy and identify the reporting route?
Check 03
Are committee appointment and tenure records current?
Check 04
Do employees and managers know who should receive a report and what happens next?
Check 05
Is access to complaint and inquiry records limited to the appropriate people?
Check 06
Is someone responsible for arranging the facilities and information the committee needs?
Check 07
Can the responsible teams locate the records needed for applicable reporting?
Next steps
Choose your next compliance step
Assess the current position, read the legal framework, or scope support for the gaps your organisation has identified.
Assess readiness
Check your organisation’s POSH readiness
Work through the detailed review prompts and record the arrangements that need attention. Keep statutory and Rules-based requirements separate from recommended controls.
List the workplaces and teams in scope. Gather current policies, committee appointment records, training records and reporting arrangements without collecting sensitive complaint material.
02
Prioritise gaps
Identify missing or uncertain arrangements. Separate legal requirements from recommended controls, and flag questions that need legal advice before deciding priorities.
03
Assign responsibilities and actions
Agree who will address each priority, what support they need and when progress will be checked. Preserve the Internal Committee’s independence in inquiry, findings and recommendations.
04
Put the agreed changes into practice
Update the relevant arrangements, communicate reporting routes and provide role-appropriate learning. Retain suitable records so the organisation can check what was delivered.
05
Maintain and review
Check outstanding actions and applicable reporting requirements. Revisit arrangements when law, locations, personnel or identified risks change. Periodic review is a recommended control, not a universal annual statutory duty.
FAQ
FAQs
POSH compliance questions organisations ask first
These general answers help employers identify issues to check against the Act, applicable Rules and their organisation’s facts. They do not replace legal advice.
What does POSH compliance involve for an employer?
It includes applicable duties under the POSH Act and Rules, along with practical controls for policy communication, committee readiness, awareness, complaint-process safeguards, confidentiality, employer operations and reporting. Which duties apply depends on the organisation and workplace facts.
Does the POSH framework matter for organisations with fewer than ten workers?
The Act provides a Local Committee route in specified circumstances, including where an Internal Committee has not been constituted because an establishment has fewer than ten workers, and where a complaint is against the employer. Confirm the correct route against the establishment and complaint facts before acting.
When is an Internal Committee required, and when may the Local Committee route apply?
Section 4 sets out the employer’s Internal Committee duty, while Section 6 provides the Local Committee route in specified cases. Workplace structure, worker count and whether the complaint is against the employer can matter; obtain fact-specific legal review where the route is uncertain.
Are training and certificates enough to establish POSH compliance?
No. Training records can evidence learning activity, but they do not by themselves establish that applicable duties, committee arrangements, complaint processes, confidentiality safeguards, employer operations and reporting are in place.
What employer duties exist beyond policy and training?
Section 19 includes operational duties concerning a safe working environment, support for the Internal or Local Committee, attendance and information assistance, certain criminal-law processes, service-rule treatment and monitoring of timely committee reports. Review the statutory text and obtain advice for organisation-specific application.
What should organisations review for reporting and records?
Review the distinct committee and employer reporting duties under Sections 21 and 22, applicable Rule 14 information, confidentiality-aware record handling, and the current state-specific filing route and deadline. Verify these details before filing.
How should multi-location organisations approach compliance structure?
Map the organisation’s workplaces, administrative units and reporting structure, then verify the appropriate committee and reporting arrangements against the Act, applicable Rules and the organisation’s facts. Do not assume one arrangement fits every structure without legal review.
About this guidance
This page provides general compliance guidance, not legal advice or a compliance certificate. Statutory and Rules-based duties, applicability and filing requirements should be checked against current official sources and the organisation’s facts with qualified professionals.
Editorial update: 2 October 2026.
Final step
Strengthen your POSH compliance framework with a clear path from review to action.
Use the checklist to identify your starting position. If you need help deciding priorities or coordinating implementation, tell us about your organisation and the areas you want to strengthen.