GEAP requirements, changes between 2022 and 2026, and key dates

GEAP requirements

Section 10 of the Gender Equality Act 2020 requires that:

(1) A duty holder must prepare a gender equality action plan that includes the following matters—

• (a) the results of the workplace gender audit;
• (b) strategies and measures for promoting gender equality in the workplace of the defined entity, based on the results of the workplace gender audit;
• (c) any other prescribed matters (see below re: a prescribed matter).

(2) In preparing a gender equality action plan, the duty holder must—

• (a) take into account the gender equality principles; and
• (b) consult with the governing body of the entity, the employees, employee representatives and any other relevant person.

(3) A duty holder must ensure adequate resources are allocated to developing and implementing the gender equality action plan.

In addition, duty holders must also use gender pay equity principles(opens in a new window) when they prepare their GEAP. This is set out in section 5A(1) of the Gender Equality Regulations 2020.

Step 4: Considering the gender equality and the gender pay equity principles, and intersectionality(opens in a new window) sets out how to consider both sets of principles.

All these requirements are clearly marked in the GEAP guidance and template.

Other actions to help you develop your GEAP are marked as ‘recommended’.

Use the GEAP checklist(opens in a new window) to check you have included all the required elements.¹

Your GEAP will reflect the size of your organisation and its capacity.

Changes between 2022 and 2026

Requirements

Learn about changes made to the requirements since 2022

Gender pay equity principles

The gender pay equity principles (opens in a new window)are a new requirement.

You must consider the gender pay equity principles in your GEAP. This is in addition to considering the gender equality principles, which has been a requirement since 2022.

Strategies and measures

Strategies and measures are more clearly defined and separated.

The Act uses the term ‘strategies’. Strategies are actions that you undertake.

Measures are the metrics you use to assess whether your strategies work.

Step 6: Developing your strategies and measures(opens in a new window) sets out guidance on both.

Supporting documents

We will not accept supporting documents in 2026. Include all required information in your GEAP.

Attestation

Your head of organisation (CEO or equivalent) must attest they have approved the GEAP.

They must also attest that your organisation will provide adequate resources to implement the GEAP.

All other GEAP requirements are the same as 2022.

Improvements

We have made other changes to better support you.

These are not required. However, they will help you to develop your GEAP.

Comprehensive GEAP guidance and additional how-to guides

You can use all or parts of the guidance where useful and feasible.

The guidance steps you through a suggested approach to developing your GEAP.

GEAP template

We strongly recommend you use the template. It follows the steps of the GEAP guidance. Using it will help reduce inefficiencies.

Performance measures

The performance measures (opens in a new window)are new.

They help you understand your progress against each indicator.

The measures are practical. They provide a benchmark to measure change.

We strongly encourage you to use these measures.

Refer to Step 6.2: Setting measures for more about setting and using measures(opens in a new window).

Key dates

Note that your GEAP must be a 4-year plan, starting from 2026. Exact dates and inclusive years at discretion of duty holders (e.g. 2026-30 or 2026-29 inclusive).

Submit your GEAP using the Commissioner’s reporting platform(opens in a new window).

Your progress report is due at the same time.

You can submit either document before this date.

Visit the 2026 progress report guidance(opens in a new window) for more information about progress reporting.

This timeline suggests when to complete each step to meet your reporting obligations:

• May 2025 – review guidance for your obligations (audit(opens in a new window), progress report(opens in a new window), GEAP)² and prepare for reporting
• June 2025 – prepare your organisation (set up systems(opens in a new window), create working groups(opens in a new window))
• July 2025 – extract and collate your audit data. Gather information about completed gender impact assessments(opens in a new window) (GIAs) and the status of strategies in your previous GEAP for your progress report. Start work on the progress reporting template.
• September – use the data quality report on the reporting platform(opens in a new window) to check your data. Submit your audit (deadline is 1 December 2025).
• October–November 2025 – analyse your audit data and begin to prepare the indicators section of your progress report
• December 2025 – finalise your progress report and start the consultation (opens in a new window)process on your audit findings. Start developing your GEAP
• January–March 2026 – develop a first draft of your GEAP in consultation with your employees, employee representatives (unions and any other representatives) and your governing body(opens in a new window)
• April 2026 – finalise your GEAP. Obtain organisational approvals. Ensure your head of organisation completes the attestation
• 1 May 2026 – submit your progress report and GEAP to the Commissioner

Footnotes

1. When developing a GEAP, you must consider your legal obligations under Commonwealth and state legislation and industrial instruments, including: the Fair Work Act 2009 (Cth) and other Commonwealth workplace relations legislation; the Equal Opportunity Act 2010 (Vic) and the Charter of Human Rights and Responsibilities Act 2006 (Vic); the Sex Discrimination Act 1984 (Cth) and the Workplace Gender Equality Act 2012 (Cth); and enterprise agreements, workplace determinations and modern awards.
2. Not all organisations that submit a GEAP need to submit a progress report. If you are unsure whether your organisation must submit a progress report, please contact enquiries@genderequalitycommission.vic.gov.au.