HR & Culture

Unconscious Bias Training

1 course1 guide3 laws & standards

Everyone relies on mental shortcuts, and at work those shortcuts show up in who is shortlisted, how performance is rated and who is seen as ready for promotion. Awareness alone rarely changes the outcome; structured decision habits do.

Our unconscious bias course teaches practical checks for high-stakes people decisions. The guides below look at what the research says works and how to connect the training to BRSR and ESG reporting.

Quick answer

No Indian law requires unconscious bias training. What the law does prohibit is the outcome of bias: discrimination in pay, recruitment and employment on grounds of gender, disability or transgender identity, under the Code on Wages, the RPwD Act and the Transgender Persons Act. Listed companies also disclose diversity and discrimination data in their BRSR. Decision-makers benefit most from training.

The course

What the law requires

No statutory mandate for bias training

There is no Act, rule or SEBI regulation in India that requires employers to run unconscious bias training. Treat any claim that it is "mandatory" with caution. The relevant law prohibits discriminatory decisions and requires certain policies and disclosures; unconscious bias training is one way to reduce the risk that everyday decisions breach those rules. The sections below set out where that risk sits.

Code on Wages, 2019: section 3 (pay and recruitment)

Section 3(1) of the Code on Wages, 2019 prohibits discrimination on the ground of gender in wages for the same work or work of a similar nature. Section 3(2)(ii) prohibits discrimination on the ground of sex while recruiting for the same or similar work and in conditions of employment, except where the law restricts women's employment in that work. These provisions have been in force since 21 November 2025. Shortlisting, offer and appraisal decisions are where bias most often turns into a section 3 problem.

Rights of Persons with Disabilities Act, 2016

Section 21 of the Rights of Persons with Disabilities Act, 2016 requires every establishment, Government or private, to notify an equal opportunity policy and register it with the Chief Commissioner or State Commissioner. For Government establishments, section 20 also prohibits discrimination in any matter relating to employment and says no promotion shall be denied merely on the ground of disability. Assumptions about what a person with a disability can do are a common form of bias in hiring and promotion.

Transgender Persons (Protection of Rights) Act, 2019

Section 3 of the Transgender Persons (Protection of Rights) Act, 2019 prohibits unfair treatment in employment and denial of, or termination from, employment of a transgender person. Section 9 bars establishments from discriminating in any matter relating to employment, including recruitment and promotion. The Act was amended in 2026 (in force from 25 May 2026), so check the current text for definitions.

Code on Social Security, 2020: maternity protection

Section 68 of the Code on Social Security, 2020 makes it unlawful to dismiss a woman during or on account of maternity absence, or to vary her conditions of service to her disadvantage. Appraisal and promotion decisions about people returning from maternity leave are a well-known point where bias can create legal exposure.

SEBI BRSR: where the outcomes are reported

Under Regulation 34(2)(f) of the SEBI LODR Regulations, the top 1,000 listed companies by market capitalisation file a Business Responsibility and Sustainability Report. The BRSR format asks for workforce composition and turnover by gender, women on the board and in key managerial roles, return-to-work and retention after parental leave, training on human rights issues, and complaints on discrimination at the workplace. These numbers show the result of many individual people decisions, which is why some companies connect bias training to their BRSR reporting. The format does not require bias training itself.

Who must be trained and how often

Because no law requires it, there is no legal audience or frequency. Practice is to focus on the people whose decisions the law regulates: hiring managers, interview panels, performance reviewers and promotion committees. Many organisations run a short module for all staff and a deeper session for decision-makers, timed just before hiring drives and appraisal cycles so the checks are fresh when they are used.

Awareness on its own rarely changes outcomes. Training works better when it gives people concrete habits, such as agreed criteria before reviewing candidates and structured evidence in appraisals. Our unconscious bias course is built around those decision checks.

AudienceDecisions at riskCommon timing
Hiring managers and interview panelsShortlisting and selection (Code on Wages s.3(2)(ii); Transgender Act s.9)Before each hiring cycle
Performance reviewersRatings and pay outcomes (Code on Wages s.3(1))Before the appraisal window
Promotion committees and leadershipPromotion and succession (RPwD Act s.20(3); Transgender Act s.9)Yearly, before promotion rounds
All employeesEveryday inclusion and speaking upInduction, then periodic refresh

Penalties and consequences

There is no penalty for not running bias training. These are the penalties for the discriminatory outcomes it aims to prevent:

BreachProvisionConsequence
Paying less than the amount due under the Code on WagesCode on Wages s.54(1)(a)Fine up to ₹50,000; repeat within five years: imprisonment up to three months or fine up to ₹1 lakh, or both
Contravening any other Code on Wages provision, such as sex discrimination in recruitmentCode on Wages s.54(1)(c)Fine up to ₹20,000; repeat within five years: imprisonment up to one month or fine up to ₹40,000, or both
Contravening the RPwD Act or its rulesRPwD Act s.89First contravention: fine up to ₹10,000. Subsequent: ₹50,000 to ₹5 lakh
Penalising a woman employee in breach of the maternity chapterCode on Social Security s.133(d)Imprisonment up to six months, or fine up to ₹50,000, or both

What good Unconscious Bias training covers

  • What unconscious bias is, and the common types: affinity, confirmation, halo and horns, attribution
  • How bias shows up in shortlisting, interviews, appraisals and promotion
  • The legal line: where biased decisions breach the Code on Wages, RPwD Act or Transgender Persons Act
  • Agreeing criteria before reviewing candidates or performance
  • Structured interviews and diverse panels
  • Evidence-based appraisal comments and calibration
  • Bias around parental leave, disability and age
  • Intersectionality: how several identities combine
  • Habits for meetings: credit, airtime and interruptions
  • How to challenge a biased decision safely and where to escalate

Our courses for this topic

CourseAudienceDurationLanguageFormat
Unconscious BiasAll Staff42 minEnglishSCORM eLearning

Laws & standards covered

  • BRSR Reporting Requirements
  • ESG Governance Standards
  • Equal Employment Opportunity Principles

Who it's for

  • All employees
  • Hiring managers
  • Performance reviewers
  • Leadership teams

Guides & insights

Frequently asked questions

Is unconscious bias training a legal requirement in India?

No. No Indian statute or SEBI regulation requires it. The law prohibits discriminatory outcomes and requires certain policies and disclosures, and training is a practical way to reduce the risk of breaching them.

Does BRSR require us to report bias training?

No. The BRSR format asks for training on human rights issues and on health, safety and skills, plus diversity data and discrimination complaints. Bias training can support those numbers but is not a separate disclosure item.

Does unconscious bias training actually work?

Knowing that bias exists does not by itself change a shortlist or a rating. Training is more useful when it leaves people with structured habits they apply inside hiring and appraisal processes, which is why our course focuses on practical checks.

Who should take it first?

Start with the people who make high-stakes people decisions: hiring managers, interview panels, appraisers and promotion committees. Then extend a shorter version to all staff.

How is this different from diversity and inclusion training?

D&I training covers the wider culture, policies and legal framework. Unconscious bias training zooms in on how individual judgements go wrong and the checks that correct them.

Which Unconscious Bias Training courses does Compliance at Workplace offer?

Unconscious Bias (42 min, for All Staff).

Which laws and standards does Unconscious Bias Training cover?

BRSR Reporting Requirements; ESG Governance Standards; Equal Employment Opportunity Principles.

Who should take Unconscious Bias Training?

All employees, Hiring managers, Performance reviewers, Leadership teams.

Can the Unconscious Bias Training be customised to our organisation?

Yes. Every course can be customised to your policies, branding and industry scenarios, and delivered on your LMS as SCORM or on our Compliance Central platform.

Sources

  1. Ministry of Labour and Employment: Code on Wages, 2019 (PDF)
  2. Department of Empowerment of Persons with Disabilities: RPwD Act, 2016 and Rules
  3. Ministry of Social Justice and Empowerment: Transgender Persons (Protection of Rights) Act, 2019 (PDF)
  4. Ministry of Labour and Employment: Code on Social Security, 2020 (PDF)
  5. SEBI: Listing Obligations and Disclosure Requirements Regulations, 2015 (as amended to 14 July 2026)
  6. SEBI: Business Responsibility and Sustainability Report format (Annexure II, July 2023)

Last updated by the Compliance at Workplace Editorial Team.

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