New Delhi – Compliance with the law on workplace sexual harassment has moved out of the human resources department and onto the board report, and enforcement in 2026 has caught up with organisations that treated it as paperwork.
The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act requires every organisation with ten or more employees to constitute an Internal Committee. That threshold has not changed. What has changed is the seriousness with which its functioning is examined.
The courts set the standard
In Aureliano Fernandes v. State of Goa, the Supreme Court issued detailed directions on how Internal Committees must be constituted and run, with emphasis on training, procedural rigour and adherence to natural justice. Subsequent rulings have widened the interpretive scope, reinforcing that access to redress must hold even where harassment crosses organisational boundaries.
The cumulative effect is that a committee which exists on paper but cannot demonstrate trained members and a defensible process is not compliance. It is a documented failure waiting to be examined.
Where the disclosure now lands
Three obligations now intersect, and companies frequently satisfy one while missing the others.
- Every Internal Committee must file an annual report with the District Officer covering complaints received, resolved and pending, and the action taken.
- Companies must confirm compliance in the Board Report under the Companies Act, 2013.
- Employers are expected to register compliance details on the SHe-Box portal, which functions as both a complaint channel and a monitoring system.
The Board Report is the one that carries governance consequence. An omission there is a filing deficiency under company law, not merely a lapse under the harassment statute, and it draws scrutiny from the Ministry of Corporate Affairs.
Why this is also a BRSR number
Complaints filed under the Act form part of the gender diversity attribute within BRSR Core, and that attribute now carries external assessment or assurance for a widening cohort of listed companies.
This creates an uncomfortable reconciliation. The complaint count filed with the District Officer, the figure stated in the Board Report and the number assured in BRSR Core should all agree. Where an organisation has been resolving matters informally to keep the reported count low, the three disclosures will not match, and the mismatch is now visible to an assurance provider.
What good looks like
A defensible position requires a properly constituted committee with an external member, documented and recent training, a written procedure that follows natural justice, and one complaint register that feeds every disclosure. Anything less is a compliance narrative rather than compliance.
Source: Sexual Harassment of Women at Workplace Act, Supreme Court directions in Aureliano Fernandes v. State of Goa, Companies Act, 2013 board reporting requirements, and the SHe-Box portal.
