SHe-Box Registration for Private Organisations: Legal Mandate or Proactive Compliance?

In recent times, there has been a significant rise in awareness around the enforcement of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“POSH Act”). Driven by judicial scrutiny and proactive administrative measures, district administrations across India have begun tightening enforcement, with particular attention to digital compliance through the SHe-Box Portal, the centralised platform for POSH implementation.

This transformation was catalysed by the Supreme Court’s landmark judgment in Aureliano Fernandes vs. State of Goa & Others (Civil Appeal No. 2482 of 2014), where the Court observed deep and persistent lapses in the enforcement of the POSH Act.

Supreme Court’s Directives: Strengthening the Compliance Framework

In Aureliano Fernandes, the Hon’ble Supreme Court criticised the poor implementation of the Act even after a decade of its passage. The Court reaffirmed that “however salutary this enactment may be, it will never succeed in providing dignity and respect to working women unless there is strict adherence to the enforcement regime and a proactive approach by all State and non-State actors.”

Key directives included:

• Time-bound verification by Central and State governments to ensure the constitution and correct composition of Internal Committees (ICs) and Local Committees (LCs).

• Public availability of committee information such as contact details, email IDs, and complaint submission procedures.

• Regular training and awareness programmes to upskill IC members and sensitise employees.

• Transparent complaint processes, from intake to final resolution, aligned with the Act’s intent.

  
  

While these directions focused primarily on public sector bodies, the Act itself makes no distinction—its provisions apply equally to private establishments.

Digital Compliance via SHe-Box: From Advisory to Enforcement

On 29th August 2024, the Ministry of Women and Child Development (MWCD) launched an enhanced version of the Sexual Harassment Electronic-Box (“SHe-Box”) Portal. The upgraded platform serves as a centralised compliance and redressal system for both government and private workplaces, offering complaint submission, tracking, and regulatory visibility into the Internal Committees functioning across India.

In March 2024, the Supreme Court, through Misc. Application Diary No. 22553/2023, further instructed District Officers to upload POSH implementation details on the SHe-Box portal. These developments clearly underscore that SHe-Box is no longer just an optional resource, it has emerged as an essential compliance infrastructure under the POSH Act.

However, various state and labour authorities are still in the process of publishing formal guidelines mandating private-sector compliance. Despite this, multiple regions have already moved ahead with binding circulars requiring registration:

• Delhi: On June 12, 2025, the Department of Women and Child Development (GNCTD) issued a public notice requiring all public and private organisations to register on the SHe-Box portal.

  
  

• Mumbai (Maharashtra): The District Women and Child Development Officer, via Public Notice DGIPR/2025-26/480, mandated that all private establishments complete registration by 15th May 2025.

  
  

• Rajasthan: Issued a comprehensive notification making registration on the SHe-Box mandatory for all government departments, PSUs, private institutions, and subordinate offices.

  
  

• Telangana has its own "T-She Box" and has long been active in mandating registration. The Women Safety Wing of the Telangana Police also actively promotes these compliance measures.

  
  

• Uttar Pradesh: The state has launched an upgraded version of the portal aimed at extending coverage to both public and private entities, with a focus on ensuring digital tracking and prompt redressal of complaints. You can read more about this initiative here.

  
  

Key SHe-Box compliance requirements for all establishments

As these mandates take effect, it's crucial for organisations to understand the specific obligations that come with SHe-Box registration. These include:

Nodal Officer Appointment

Every establishment must designate a Nodal Officer responsible for ensuring compliance with POSH Act provisions via the SHe-Box Portal. Responsibilities include:

• Regularly updating IC/LC details.

• Tracking the status of complaints filed via the portal.

• Submitting the Annual POSH Report for each calendar year via the portal.

• Update information on employee sensitisation workshops and trainings

• Update details of IC member trainings.

  

Registration of Head Office

All employers, whether public or private, must register their head office on the portal. The registration must include:

• Organisation details.

• Upload of registration certificate, GST certificate, and PAN card.

• Verification of establishment type and IC constitution.

  
  

Proactive Compliance: The Way Forward

Some organisations may still be waiting for official state-level mandates before registering. However, the structure and intent of the POSH Act, backed by Supreme Court directions, and reinforced by state-level notices, make it clear that delaying registration poses serious legal and reputational risks.

Proactive registration on the SHe-Box portal is no longer just good practice—it is a legal obligation and a reflection of a safe and equitable workplace culture. Failure to register effectively blocks complainants from accessing redressal through the portal and may amount to non-compliance with the POSH Act.