POSH Complaints Disclosure — BRSR Core Attribute

What this attribute is

POSH Complaints Disclosure is one of the nine BRSR Core attributes that SEBI requires every Top-1,000 listed entity to subject to independent reasonable assurance. It is one of three Core attributes under NGRBC Principle 3 — Wellbeing of Employees, alongside Spend on Wellbeing and Female Wages Share.

This is the most structurally complex of the nine BRSR Core attributes — it is a multi-component disclosure, not a single number. It is also the highest-sensitivity disclosure on any BRSR: built on top of the statutory framework of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, with confidentiality requirements that shape both the filing and the assurance procedures.

The disclosure flows from the entity’s Internal Committee (IC) records — the same records that feed the IC’s annual report to the District Officer under the POSH Act. BRSR is the public-facing summary; the IC’s minutes and complaint register are the underlying audit-trail.

The POSH Act framework — quick orientation

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 establishes the regulatory framework that the BRSR Core POSH disclosure sits on top of. The key elements relevant to BRSR reporting:

• Internal Committee (IC) requirement — every employer with 10 or more employees must constitute an IC under §4 of the Act. The IC is the body that receives, investigates, and disposes of complaints.
• Disposal timeline — the IC must complete inquiry and submit its report within 90 days of receiving a complaint (§11(4)).
• Annual report to District Officer — every employer must submit an annual report to the District Officer summarising number of complaints received, disposed-of, and pending; action taken; and workshops/awareness programmes (§21–22).
• Confidentiality — identity of the complainant, respondent, witnesses, and any details of conciliation or inquiry proceedings cannot be published or made known to the public, press, or media (§16). Penalty for breach: ₹5,000 fine plus disciplinary action.
• Coverage — the Act’s definition of “employee” under §2(f) includes persons engaged on regular, temporary, ad-hoc, or daily-wage basis, directly OR through an agent including a contractor — meaning the IC’s jurisdiction extends to contractor-engaged women working at the entity’s premises.

The BRSR Core POSH disclosure is derived from, not separate from, this statutory framework. The IC’s complaints register is the source-of-truth.

The four disclosure components

SEBI/NSE BRSR Core material treats POSH as a multi-component disclosure rather than a single metric:

Component	What it captures
Total complaints filed during the year	Count of complaints formally received and recorded by the IC during the reporting financial year
Complaints upheld	Count of complaints for which the IC found the allegation substantiated upon inquiry
Complaints pending at year-end	Count of complaints open as of FY-end (received but inquiry not yet completed)
Complaints on POSH as % of female employees and workers	Percentage metric — see formula below

All four components are reported together. A clean BRSR Core POSH disclosure presents the complete picture: the absolute numbers AND the percentage, with the percentage providing comparability across entity sizes.

The percentage formula

POSH Complaints (%) = (Complaints filed during the year)
                    ÷ (Female employees and workers, per the BRSR Core
                       denominator convention in the applicable taxonomy /
                       guidance) × 100

Two specifics worth pinning:

• Numerator — complaints filed during the year (the same number reported as Component 1 above), not complaints upheld, not complaints pending. The metric measures incidence, not adjudication outcome.
• Denominator — female employees and workers, with the exact calculation basis prescribed by the BRSR Core taxonomy and the SEBI Industry Standards on Reporting of BRSR Core (December 2024 circular). SEBI’s December 2024 circular specifically clarified the POSH-percentage denominator and the definition of “complaints upheld” — entities should follow the convention prescribed there and in the current MCA-published BRSR taxonomy, and apply it consistently year-on-year. Whether the convention uses an averaged figure, a year-end snapshot, or another basis is a question to confirm against the current SEBI / MCA-published guidance, not from third-party summaries.

The cohort scope (employees + workers, female only) should be consistent with the Section A workforce table — see the cohort-scope note below.

What “complaint” means for this disclosure

A complaint is counted when formally received and recorded by the Internal Committee under the POSH Act. The trigger is IC receipt and registration in the complaints register, not the moment a verbal grievance is raised informally to a manager.

What’s NOT counted in the BRSR POSH disclosure:

• Informal grievances or feedback raised through other channels and not escalated to the IC
• Anonymous reports that do not result in an IC-recorded complaint (handling of anonymous reports is itself a documented entity policy)
• Complaints under other categories — discrimination, harassment that does not meet the POSH definition, general workplace grievances. These belong in the broader Principle 3 grievance-redressal disclosures, not the POSH Core attribute

For complaints that are withdrawn (after submission, before or during inquiry), treatment depends on the entity’s documented IC policy on withdrawal handling and how those events are recorded in the IC register and the annual report to the District Officer. The entity’s policy should be applied consistently and the BRSR disclosure should reconcile to the IC’s records on the same basis.

The IC’s complaints register and meeting minutes are the documentary audit-trail. The reconciliation between the IC register, the IC’s annual report to the District Officer, and the BRSR draft disclosure is the highest-priority pre-engagement task.

Coverage scope — two separate questions

The IC’s statutory jurisdiction and the BRSR Core cohort scope are two separate questions that need to stay separate:

• Statutory IC jurisdiction (POSH Act §2(f)). The Act’s broad definition of “employee” covers women engaged on regular, temporary, ad-hoc, or daily-wage basis, directly or through an agent including a contractor. The IC therefore has jurisdiction to receive complaints from contractor-engaged women working at the entity’s premises, and a well-functioning IC records and processes those complaints the same way as direct-employment complaints. This is a statutory rule, not an entity policy.
• BRSR Core cohort scope (entity policy). Whether contractor-engaged women are included in the BRSR percentage denominator (and whether their complaints, if recorded by the IC, are included in the numerator) is a separate cohort-scope question. The right answer is consistency: follow the entity’s documented workers-cohort definition from Section A, apply it the same way to both the numerator and the percentage denominator, and disclose the basis. Including contractor-engaged women in the IC count but excluding them from the percentage denominator (or vice versa) is the most common cohort-mismatch error on this disclosure.

Source-document evidence

The full evidence-document inventory is on Document Evidence Requirements. For the POSH disclosure specifically:

• IC composition records — current IC members with appointment letters, including the external NGO/legal-expert member required under §4(2)(c) of the Act
• IC meeting minutes for the full reporting year — every meeting, every complaint received, action taken, disposition
• Complaints register maintained by the IC — chronological log
• Annual report to the District Officer under §21 of the POSH Act for the reporting year
• Action-taken records (anonymised in workpapers) — IC’s recommendations and the entity’s implementation
• POSH-awareness training records — completion logs (also feeds the broader Principle 3 training disclosure)
• External-counsel correspondence (if any) on POSH matters during the year — auditor reviews to confirm no complaints surfaced outside the IC channel

The single highest-value pre-engagement task: reconciling the IC register, the IC annual report to the District Officer, and the BRSR draft disclosure. Three documents that must agree on the same numbers.

Worked example

Illustrative only — not representative of a typical company. POSH-complaint volumes vary by sector, workforce composition, awareness levels, and reporting culture. A higher count is not inherently bad (it can reflect a working IC and a culture where complaints are surfaced); a lower count is not inherently good (it can reflect under-reporting). The numbers below are constructed to make the calculation structure clear.

Same diversified mid-cap manufacturer used in the prior worked examples, FY 2024-25:

Step 1 — Complaints during the year (from IC register)

Component	Count
Complaints filed during the year	3
Complaints upheld upon inquiry	1
Complaints pending at year-end	1
Complaints carried forward from prior year (separate disclosure)	0

(Inquiry on the 1 pending complaint was within the 90-day statutory window at year-end — disclosed as such in the BRSR text.)

Step 2 — Denominator: female employees + workers

The exact basis (averaged headcount, year-end snapshot, or another convention) must be the basis prescribed by the BRSR Core taxonomy and the SEBI December 2024 Industry Standards circular — refer to those for the current convention. For illustration only, the entity’s tracked figures look like:

Cohort	Beginning of year	End of year
Female employees (direct payroll)	412	446
Female workers (per documented cohort definition)	178	204
Total female workforce	590	650

If the prescribed BRSR Core convention applies an average of beginning-of-year and end-of-year, the denominator works out to (590 + 650) ÷ 2 = 620. The entity must verify the prescribed convention against the December 2024 SEBI circular and the current MCA-published taxonomy before locking the figure.

Step 3 — Percentage (illustrative)

Using the illustrative averaged denominator of 620:

POSH Complaints % = 3 ÷ 620 × 100 = 0.48%

Step 4 — Disclosure summary

The BRSR filing carries the four components: 3 complaints filed, 1 upheld, 1 pending at year-end, plus the percentage on the prescribed-basis denominator. The IC convening record and absence-of-complaints register (where applicable) are retained as workpaper evidence under the Principle 3 grievance-redressal Essential indicator.

Confidentiality and redaction

Two confidentiality regimes apply to this disclosure: the POSH Act §16 (statutory confidentiality of complainant, respondent, witnesses, and inquiry details) and the ICAI professional confidentiality framework (assurance practitioner’s general duty).

Standard practice for the BRSR Core engagement on POSH:

• The BRSR filing itself carries only counts and percentages — no names, no identifying details, no narrative on individual cases beyond categorical action-taken summaries
• IC minutes reviewed by the assurance partner under a written confidentiality undertaking; review is limited to engagement-team members on a need-to-know basis
• Workpaper extracts, where retained, redact identifying information (complainant initials only, or a complaint-reference number rather than name)
• Engagement-letter scope explicitly addresses the POSH-confidentiality protocol so both the entity and the assurance partner have a documented basis for the workpaper-handling approach

The assurance opinion attests the count and percentage; it does not opine on the underlying merits of any complaint, the IC’s adjudication, or the appropriateness of action taken. Those are the IC’s and the entity’s responsibilities under the POSH Act, not the assurance practitioner’s.

Common practice patterns in audit

Common practice patterns observed in BRSR Core assurance engagements — not SEBI-recognised categories of finding:

1. IC register vs BRSR draft mismatch. IC minutes log N complaints; BRSR draft shows N-1 (or N+1). Almost always a transcription or scope-of-period error rather than intentional under-reporting; resolved by reconciling to IC primary records.
2. Cohort-scope mismatch in the percentage. Contractor-engaged women included in the IC complaint count but excluded from the percentage denominator (or vice versa). The cohort scope must be the same on both sides.
3. Year-end snapshot used as denominator instead of average. A simple but material error in years with significant hiring/attrition. Re-calculation with the average can shift the percentage materially.
4. Complaints scope confusion. Disclosure includes general grievances or non-POSH complaints (workplace conflict, bullying, performance disputes) in the POSH count. The POSH Core attribute is specifically sexual-harassment complaints under the POSH Act; other grievance categories belong in the broader Principle 3 grievance-redressal disclosure.
5. Zero complaints with no IC convening record — process-control observation. Reporting zero is a legitimate disclosure value. The Act’s IC composition and annual reporting obligations apply regardless. From an assurance perspective, a year of zero complaints with no IC meetings during the year is a process-control observation that the assurance partner may surface — not because the zero is invalid, but because the operating effectiveness of the IC process becomes harder to evidence without convening records.
6. Pending vs. carried-forward — internal IC tracking consistency. Complaints open at year-end show in one year’s disclosure and continue into the next year’s records. The exact labelling and cross-year treatment should follow the entity’s IC records and annual report to the District Officer, applied consistently. This is an internal tracking consistency point rather than a SEBI-defined cross-year categorisation.

XBRL filing

This attribute is filed in the BRSR XBRL instance document under the relevant elements from the MCA-published BRSR taxonomy module. POSH being a multi-component disclosure, multiple XBRL elements are involved (one per component: filed, upheld, pending, percentage). Element names and unit references should be verified against the current MCA taxonomy version before generating the instance document. Both current-year and previous-year context references must be populated.

See XBRL Taxonomy for BRSR for the structural overview.

How this attribute rolls up into the BRSR Core engagement

This is one of the three Core attributes under Principle 3. The signed BRSR Core assurance report attests the four components (filed, upheld, pending, percentage) to reasonable assurance under SAE 3000 (Revised). Workpapers retained by the assurance partner cover the IC register reconciliation, the District Officer annual report cross-check, the cohort-scope alignment between numerator and denominator, and the POSH-confidentiality protocol applied during the engagement.

For the engagement that produces the signed assurance opinion, see BRSR Core Assurance. For SME suppliers being asked by their Top-1,000 listed customer to provide assured POSH disclosure data as part of value-chain reporting, see BRSR Value Chain Verification.

Related reading

• NGRBC Principle 3 — Wellbeing of Employees — parent pillar
• Spend on Wellbeing as % of Revenue — sibling P3 Core attribute
• Document Evidence Requirements — full evidence checklist
• XBRL Taxonomy for BRSR — XBRL filing structure
• BRSR Core Assurance — service
• BRSR Value Chain Verification — service