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Employment & Labour · 5 March 2026

Training the Internal Committee: What the POSH Rules Require and Why It Matters

An overview of the training and capacity-building obligations around a POSH Internal Committee, covering member orientation, workforce awareness sessions and periodic refreshers.

By S&S Co. Advocates & Solicitors · Published 5 March 2026 · Informational content, not legal advice: see our disclaimer

Why Training Is Not Optional

Constituting an Internal Committee on paper is only the first step in compliance. The Sexual Harassment of Women at Workplace Rules, 2013 and the POSH Act together contemplate an employer taking active steps to create workplace awareness and to equip the Committee itself to competently handle complaints, rather than treating the Committee as a dormant body that only becomes relevant once a complaint is filed.

Orientation for Committee Members

Newly appointed Internal Committee members, including the external member, benefit from a structured orientation covering the statutory framework, the definition of sexual harassment and workplace under the Act, the procedure for recording a complaint, principles of natural justice to be followed during an inquiry, confidentiality obligations under Section 16, and the drafting of a reasoned inquiry report. Members who have never conducted an inquiry before are better placed to handle one fairly and defensibly if this grounding is in place before a complaint arrives, rather than being learned on the fly during an actual proceeding.

Workforce-Wide Awareness

Separately from Committee member training, employers are expected to conduct periodic workplace awareness sessions for the general workforce, covering what constitutes sexual harassment, how and to whom a complaint may be made, the existence and composition of the Internal Committee, and the protections available to a complainant including confidentiality and protection from retaliation. Many organisations conduct this awareness training at onboarding and refresh it annually, often alongside other compliance training.

Periodic Refreshers and Scenario-Based Training

Given that Committee membership typically rotates every three years, and that the law in this area continues to develop through judicial interpretation, organisations generally find it useful to schedule periodic refresher sessions for existing Committee members, covering recent developments and working through anonymised scenario exercises, rather than relying solely on the initial orientation given years earlier.

Documenting Training

Maintaining records of when training was conducted, who attended, and what it covered is useful not only for internal governance but also because the adequacy of an employer's preventive measures, including training, can become relevant if an inquiry or its procedure is later challenged.

Frequently Asked Questions

Is Internal Committee member training legally mandatory?

The POSH Rules contemplate capacity-building and awareness generation as part of an employer's preventive obligations under the Act, and the adequacy of training can become relevant to how a Committee's competence and procedure are assessed, even where no single provision prescribes a fixed training curriculum or hours.

How often should workforce-wide POSH awareness training be conducted?

Most organisations conduct it at onboarding and refresh it annually, though the Act does not prescribe a fixed frequency; the goal is that employees remain aware of the complaint mechanism and their rights on an ongoing basis, not only once.

Does the external member need separate training from internal members?

The external member benefits from the same orientation to the employer's specific policy and procedure as internal members, even though they typically bring independent subject-matter familiarity with sexual harassment issues from their own professional background.

References & Further Reading

This article references the following statutory provisions. Readers should always verify current rules, fees and timelines against the applicable statute and rules as amended, since these are revised from time to time.

  1. Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, as amended.
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