AstraLex Insights — Issue 4

The Committee That Only Matters When It's Tested

POSH compliance is one of those obligations that feels administrative right up until it isn't. This issue looks at what actually makes an Internal Committee work, not just exist.

Regulatory Watch

State labour departments have continued to increase inspection activity around POSH Internal Committee compliance in the past year, particularly the external-member composition requirement. Companies that haven't reviewed their IC composition in the last 12 months should treat this as a live audit risk, not a formality.

Featured Read

POSH Compliance in 2025: Building an Internal Committee That Actually Works →

The composition requirement most companies miss, the 90-day inquiry timeline that isn't optional, and the operating discipline that separates a compliant committee from a trusted one.

The 60-Second Tip

Check your Internal Committee roster against one question: does it currently include a genuine external member from an NGO or with relevant legal expertise — not just a senior employee filling that seat informally? If not, this is a same-week fix, not a project.

Ask AstraLex

Q: How often does our POSH Internal Committee actually need to be reconstituted?

There's no fixed statutory interval, but best practice is an annual review — checking that all members, including the external member, are still active and available, and refreshing training even if the roster hasn't changed. Turnover among internal members is the most common reason a committee quietly becomes non-compliant.

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RS
Written by RS

20+ years in commercial & corporate practice — in-house at BT, Oracle and Dell before founding AstraLex.