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Who must sit on the ICC
An Internal Complaints Committee needs a minimum of four members: a Presiding Officer who must be a woman employed at a senior level, at least two members from among employees committed to the cause of women or with relevant experience in social work or legal knowledge, and one external member — typically from an NGO or an organisation working on women's issues, or someone with relevant legal expertise. At least half of the total ICC members must be women. For companies with offices across multiple locations, a separate ICC (or Local Committee, where applicable) is generally required for each administrative unit.
Where companies get formation wrong
The most common mistakes we see: appointing an external member who has no real familiarity with POSH proceedings, failing to formally document ICC member tenure (the term is typically capped at three years), and not refreshing the committee when members leave the organisation — leaving the ICC technically non-compliant without anyone noticing. A properly constituted ICC should also have its composition, contact details, and reporting process clearly communicated to every employee, not buried in an onboarding document nobody reads again.
Frequently asked questions
What are the requirements for an ICC under the POSH Act?
An ICC must have a minimum of four members. The Presiding Officer must be a senior female employee. At least two members must be employees committed to women's causes or with social work experience. One member must be an external expert from an NGO, legal background, or someone familiar with women's issues. The external member must not be from within the organisation.
Who can be the Presiding Officer of the ICC?
The Presiding Officer of the ICC must be a woman employed at a senior level at the workplace. She must be from the same workplace if possible. If no senior female employee is available, the Presiding Officer can be nominated from another office or administrative unit of the same organisation.
How long is the term of ICC members?
ICC members serve a term of three years from the date of nomination or appointment. After the term expires, members must be re-nominated or replaced. Organisations should track ICC member tenures to ensure continuity and avoid gaps in the committee.
Can ICC members be from outside the organisation?
The POSH Act requires at least one ICC member to be from outside the organisation — specifically from an NGO committed to the cause of women, a legal background, or someone with relevant expertise. The remaining members must be employees of the organisation.
What training must ICC members receive?
ICC members must be trained on the provisions of the POSH Act, complaint handling procedures, confidentiality requirements, inquiry processes, and trauma-informed approaches. Untrained ICC members conducting inquiries can expose the organisation to legal challenge. POSH training for ICC members should be repeated when new members join.
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