Filing Your PoSH Annual Compliance Report (ACR) for the First Time – A Practical Playbook for Organisations

For most organisations, the first ACR filing does not fail because of intent—it fails because teams are unsure what to check, what to collate, and how to approach the process.

This playbook is designed as a ready guide. You can read it end-to-end or use it as a reference checklist when preparing your first PoSH Annual Compliance Report.

Step 1: Confirm That You Are Required to File

Before anything else, establish whether your organisation is required to file an ACR.

You are expected to file if:

• Your organisation has 10 or more employees at any point during the year
• You are required to constitute an Internal Committee under the PoSH Act

This applies:

• Even if no complaints were received
• Even if the IC was formed part-way through the year

If an IC exists (or should exist), an ACR follows.

Step 2: Take Stock of What the ACR Reflects

The ACR is not a standalone form. It reflects everything your organisation did—or did not do—through the year in relation to PoSH compliance.

Before filling anything, pause and review:

• When was the IC constituted?
• Was it formally documented?
• Were awareness or orientation sessions conducted?
• Were records maintained?

This stock-taking step prevents rushed or inaccurate reporting later.

Step 3: Verify Your Internal Committee Details

One of the first things the ACR reflects is whether the IC exists in the manner required by law.

Confirm that:

• The IC was properly constituted during the reporting year
• The Presiding Officer and members were formally appointed
• An External Member was empanelled
• Any changes in IC composition during the year were recorded

If the IC was constituted mid-year, report accurately for the period it existed. The focus is truthful disclosure, not retroactive perfection.

Step 4: Collate Awareness and Training Information

The ACR requires organisations to disclose whether awareness activities were conducted during the year.

For first-time filers, this usually means gathering:

• Dates of employee awareness sessions
• Mode of training (in-person, virtual, e-learning)
• IC orientation or training sessions, if any

If activities were limited, document what did occur. The ACR is a disclosure, not an audit.

Step 5: Review Complaint-Related Data Carefully

This is often the most sensitive section for first-time filers.

Before reporting:

• Confirm whether any complaints were received during the year
• Check whether any complaints were pending at year-end
• Ensure timelines and outcomes were documented accurately

If no complaints were received, report zero. A zero-complaint year is still a valid disclosure.

Avoid assumptions, informal recollections, or verbal confirmations—accuracy matters here.

Step 6: Check Documentation and Record-Keeping

The ACR indirectly reflects whether records were maintained in line with expectations.

As part of your first filing, ensure:

• Appointment letters and IC documentation are on record
• Training and awareness records exist
• Enquiry documentation (if any) is securely stored
• Access to sensitive records is restricted

This step often reveals gaps—and that is precisely why the first ACR is important.

Step 7: File and Track the Submission

Once the report is prepared:

• Submit it to the appropriate District Officer
• Retain proof of submission
• Record the filing date internally

For first-time organisations, it helps to treat this as a repeatable process, not a one-off task.

Step 8: Use the ACR to Plan the Next Year

The real value of the first ACR lies in what it shows you.

After filing:

• Identify gaps in training, documentation, or systems
• Plan awareness and IC activities earlier in the year
• Put simple tracking mechanisms in place
• Ensure IC reviews are scheduled, not reactive

Most organisations become significantly stronger in their second year—not because the law changes, but because the first ACR creates visibility.

Key Reminders for First-Time Filers

• Filing is mandatory; preparedness is strategic
• Zero complaints does not mean zero responsibility
• Transparency matters more than appearances
• The ACR is a compliance checkpoint, not a fault-finding exercise

Closing Note

Your first PoSH Annual Compliance Report is not about demonstrating perfection. It is about demonstrating intent, structure, and accountability.

When approached as a playbook rather than a formality, the ACR becomes one of the most useful tools for strengthening PoSH compliance year after year.

Need professional help? Reach out to Ungender’s compliance team at contact@ungender.in with the subject line “ACR Submission”