Duty holders must make reasonable and material progress against the workplace gender equality indicators every two years.
However, the Act recognises that making progress on the workplace gender equality indicators is not always a simple task. It can be influenced by a range of factors.
Duty holders can refer to these factors when reporting on their progress. This allows them to highlight the challenges they encountered and identify areas for improvement.
The Commissioner considers these factors when assessing compliance.
Note that the examples below are broad categories. When using the factors in their progress reports, duty holders will need to:
- select the factor(s) that are relevant to their organisation
- describe their specific situation
- explain how the factor(s) affected their progress.
The factors that may affect reasonable and material progress are:
- the size of the duty holder, including the duty holder's number of employees – e.g. headcount, the number of full‐time equivalent employees, service area, customer base, and scope of operations
- the nature and circumstances of the duty holder, including any barriers to making progress – e.g. dealing with the impacts of a local disaster, economic conditions, or technological changes
- requirements that apply to the duty holder under any other Act, including an Act of the Commonwealth – e.g. emergency regulations, such as laws or regulations relating to disasters or public health emergencies
- the duty holder's resources – e.g. the assets available, access to technology
- the duty holder's operational priorities and competing operational obligations – e.g. addressing technological disruptions, or merging with another organisation.
- the practicability and cost to the duty holder of making progress – e.g. a small organisation in a rural community may have limited capacity to deal with gendered segregation in its workforce.
- genuine attempts made by the duty holder to make progress – e.g. showing clear intentions, developing well-considered strategies and measures, and acting on feedback.
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