Common Mistakes Organisations Make in Their First PoSH Annual Compliance Report Filing 

At Ungender, we usually enter conversations with organisations when they are preparing to file their PoSH Annual Compliance Report for the first time. By this stage, most teams are committed to compliance—but unsure about how the ACR fits into the larger PoSH framework.

What we see repeatedly is not neglect, but misinterpretation. The ACR is often treated as a form to be completed, rather than a reflection of the year gone by. Below are some of the most common patterns we observe, and how we encourage organisations to approach them differently.

Treating the ACR as a Year-End Form

For many first-time filers, the ACR appears suddenly—towards the end of the year—triggering a scramble to gather information. Teams try to reconstruct whether awareness sessions happened, when the IC was constituted, and what documentation exists.

From our experience, the difficulty here is not filing the report, but retrospective reconstruction.

What this usually looks like

• Scrambling for dates and attendance details
• Relying on memory instead of records
• Rushing to “fill gaps” close to the deadline

How we encourage organisations to think about it
The ACR works best when treated as a year-long log that is summarised at the end—not rebuilt at the last moment.

Assuming No Complaints Means Nothing to Report

One of the most frequent questions we receive is: “We didn’t receive any complaints—do we still need to file?”

This misunderstanding stems from viewing the ACR as a complaint-reporting mechanism, rather than a compliance disclosure.

What often gets missed

• The ACR also reports IC constitution
• Awareness and training efforts are part of the disclosure
• Preparedness matters, even in the absence of cases

Our perspective
Zero complaints is still a valid data point. The ACR reflects readiness, not just incidents.

Overstating Compliance to Appear Complete

In some first-time filings, we see organisations list activities that were planned but never conducted, or processes that exist only in theory. This usually comes from discomfort rather than intent.

Teams worry that acknowledging gaps will reflect poorly on them.

Why this is risky

• Inaccurate disclosures weaken credibility
• Gaps tend to surface later, not disappear
• First-year filings are expected to show learning curves

What we recommend instead
Treat the ACR as a truthful snapshot. Transparency in the first year sets a stronger foundation than overstatement.

Underestimating the Importance of Documentation

Another recurring pattern is reliance on verbal confirmation or institutional memory. When teams change, or when clarity is required later, the absence of records becomes visible.

Where organisations struggle

• Missing appointment letters
• Incomplete training records
• Informal tracking of activities

Our guidance
Documentation is not an administrative burden—it is what protects the organisation and the IC long after the filing is complete.

Confusing Filing with Compliance

Once the ACR is submitted, many organisations feel a sense of completion for the year. This often delays preparation for the next cycle.

What this leads to

• No planning for upcoming awareness sessions
• IC reviews pushed indefinitely
• Repeat stress the following year

How we frame this
Filing completes a requirement. Compliance is continuous.

Waiting Too Long to Start

Timing is one of the most avoidable challenges we see. First-time filers often start too late, increasing pressure and reducing accuracy.

Common signals

• Rushed internal coordination
• Incomplete data collection
• Last-minute clarifications

Our suggestion
Starting even a few weeks earlier—with a simple checklist—changes the entire experience of the first filing.

Unclear Ownership Within the Organisation

In many organisations, responsibility for the ACR sits ambiguously between HR, Legal, and Compliance. This lack of clarity often causes delays.

What works better

• Clear ownership with shared inputs
• Defined accountability for submission
• Early coordination between teams

Treating the First ACR as a One-Time Exercise

Some organisations assume that once the first ACR is filed, the hardest part is done. Without systems, this assumption rarely holds.

What we encourage

• Use the first filing to set up repeatable processes
• Create basic tracking mechanisms
• Plan the year with compliance in mind

A Closing Note from the Ungender Team

We rarely see a perfect first ACR—and that is entirely expected.

What matters is that the filing is honest, structured, and reflective of actual practice. When organisations approach the ACR as a learning moment rather than a fault-finding exercise, it becomes one of the most effective tools for strengthening PoSH compliance over time.

At Ungender, we see the first ACR not as an endpoint, but as the beginning of consistent, confident compliance.

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