Understanding State-Specific Deadlines, Labour Law Involvement & Supreme Court Mandates (CY 2025)
The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act) mandates every employer to file an Annual POSH Report with the District Officer for the preceding calendar year (January 1 – December 31). While the statute is silent on one uniform national deadline, states and districts have issued their own official cutoff dates, resulting in two widely followed timelines:
🔴 January 31
🟡 February 28
Missing these deadlines can lead to heavy penalties, labour-law notices, and even license cancellation. With the Supreme Court’s 2025 directive strengthening enforcement, the Annual Report for CY 2025 is more critical than ever.
Below is the state- and district-specific breakdown, compliance rules, and filing guidance (CY 2025).
1. Key State/District-Specific Deadlines & Rules (CY 2025)
| State / District | Key Updates for Annual Report CY 2025 | Filing Deadline (CY 2025 Report) |
|---|---|---|
| Gurugram / Haryana | Historically accepts Annual Reports until Feb. Labour Department circulars consistently extend deadlines due to district-level data consolidation. Employers must file separately for each Gurugram zone. | February 28, 2026. (Past 3 years the February deadline has been consistently followed.) |
| Delhi / Other Major Cities | Clear direction from DC offices: Filing must be completed by Jan 31. Delhi typically issues reminders via email, local website updates & DC office circulars. No extended window for 2025 at the time of writing. | January 31, 2026. (This is the official date followed by Delhi District Officers.) |
| Maharashtra (Mumbai / Pune) | District WCD and Labour authorities follow a split schedule. Larger districts like Mumbai & Thane follow early submission; Pune district accepts until late February. | Varies: January 31 (Mumbai/Thane) and February 28 (Pune and select districts). Always confirm with local DO. |
| Tamil Nadu / Karnataka | No late-Feb circulars in recent years. Reports expected by January 31 each year. IC details required to be updated annually on district portals. | January 31, 2026 |
| General Mandate (PAN-India) | For states with no circulars, January 31 remains the default nationally accepted practice. Nil Reports still mandatory. | January 31, 2026, unless District Officer issues an extension. |
POSH ANNUAL REPORT CY 2025 FILING DEADLINES (AT A GLANCE)
GURUGRAM
Deadline: FEB 28, 2026
DELHI / PAN-INDIA (Default)
Deadline: JAN 31, 2026
MULTI-LOCATION RULE (HIGHLY IMPORTANT):
Separate Reports MUST be filed for EACH district where your organisation has 10+ employees.
This is the single most common oversight that leads to penalties.
Examples:
- A company with offices in Mumbai (50 employees) and Pune (60 employees) must file two separate Annual POSH Reports (one for each district).
- A company headquartered in Delhi but with branch offices in Gurugram and Bengaluru must file 3 separate reports.
2. Multi-Location Compliance Mandate (CY 2025)
| Scenario | Compliance Action Required |
|---|---|
| Head Office in One District Only | File one Annual Report to that District Officer. |
| Branches Across Multiple Districts | File SEPARATE Annual POSH Reports in each district where employee strength ≥ 10. |
| Example 1: HO in Delhi → Branches in Gurugram & Pune |
1. Delhi DO Report (HO) 2. Gurugram DO Report 3. Pune DO Report |
| Example 2: HO in Mumbai → Branch Office in Thane |
1. Mumbai DO Report 2. Thane DO Report |
Advice for Multi-location Corporates
- Identify Employee Count District-Wise
- Decentralize POSH Reporting
- Obtain Submission Proof (scanned receipt / email acknowledgement)
3. What Must Be Included in the CY 2025 Annual POSH Report
Mandatory data fields (Rule 14 & Rule 16):
Number of complaints received
Number of cases disposed
Pending cases & ageing
Workshops conducted
Awareness sessions held
IC meetings conducted
Nature of action taken
NIL report (if no complaints)
Updated IC constitution details
For 2025:
Attach proof of training, calendars, posters, and reconstitution certificates.
Ensure your organisation maintains evidence of POSH training for employees in Delhi NCR, as these are now actively reviewed by authorities. Companies working with GrowthSource often receive structured guidance for such documentation.
4. Penalties for Missing 2025 POSH Deadlines
(Include the “heavy penalties” line you requested)
Failure to file the Annual POSH Report for CY 2025 can attract heavy statutory penalties, including:
₹50,000 fine for first-time non-compliance
Under Section 26 of the POSH Act.
Higher penalties for repeated violations
District Officers may initiate stricter action for chronic defaulters.
Cancellation of business license
Labour authorities may refuse:
- Shop & Establishment license renewals
- Trade license renewals
- CLRA registrations
Corporate liability (post July 2025)
Under the Companies (Accounts) Second Amendment Rules, 2025, all companies must disclose POSH complaint data in the Board’s Report.
Non-disclosure = violation of the Companies Act.
In NCR districts, authorities increasingly verify whether organisations have completed mandatory POSH training for employees in Delhi NCR, especially where compliance partners like GrowthSource are supporting submissions.
5. Latest Supreme Court Ruling (2025): Why Compliance is Non-Negotiable Now
In its 2025 landmark judgment, the Supreme Court issued strict orders to enforce POSH implementation nationwide.
Key Directions:
- District-wise POSH compliance survey to be completed in 6 weeks
- Mandatory verification of Internal Committees under Section 4
- Uploading compliance data on the SHe-Box portal
- Immediate action against organisations lacking ICs
- Labour Departments empowered to conduct sudden inspections
- External members of IC must be qualified & active
Impact on CY 2025 reporting:
District Officers are now cross-verifying Annual Reports, training proof, and IC credentials. This includes validating POSH training for employees in Delhi NCR, especially for multi-location companies.
6. Final Checklist for Filing Your POSH Annual Report (CY 2025)
✔ Confirm District deadline (Jan 31 or Feb 28)
✔ Reconstitute the Internal Committee
✔ Conduct POSH trainings & maintain proof
✔ Prepare the Annual Report (CY 2025 format)
✔ File separately for each district
✔ Submit online/offline to District Officer
✔ Keep digital & physical proofs
✔ Update Company Board’s Report (post-July 2025 rule)
FINAL WORD
The 2025 POSH compliance cycle is more stringent than any previous year.
With state-specific deadlines, labour law enforcement, district-level inspections, and the Supreme Court’s 2025 directives, filing your Annual POSH Report on time is not just required — it is legally unavoidable.
To stay safe, employers should treat January 31, 2026 as the default national deadline unless a district explicitly extends it to February 28, 2026.
