2026 gender equality action plan (GEAP) guidance

Overview

The GEAP helps your organisation:

• understand gender equality and why it is important
• use the 7 indicators(opens in a new window) to find out about gender equality in your workplace
• take action to improve gender equality
• measure progress to stay on track.

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Why this work is important

Your GEAP is a plan to improve gender equality in your workplace. It aims to make meaningful changes.

It helps you address the root causes of gender inequality. This will lead to long-term improvements.

This is called a gender-transformative approach.

It means ending bias in your organisation. This includes organisational rules, decisions, policies, practices and gendered stereotypes.

Gender inequality in the workplace is caused by organisational systems. It happens when these systems do not consider people of different genders.

View Our Watch’s video on Workplace equality and respect: standards for your organisation(opens in a new window). This will help you better understand workplace equality and respect.

Visit the Our Watch website(opens in a new window) for more resources on workplace gender equality, including:

• Workplace equality and respect standards(opens in a new window)
• Workplace equality and respect: how-to guide(opens in a new window)
• Workplace positive duty standards(opens in a new window)

Objectives of the Act

The objectives of the Gender Equality Act 2020 are to:

• promote and encourage gender equality
• improve the status of women
• help identify and remove systemic causes of gender inequality. This includes in policies, programs and delivery of services in workplaces and communities
• recognise that other forms of disadvantage or discrimination make gender inequality worse. This includes characteristics such as Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and other attributes
• create structural change to:
  • redress disadvantage
  • prevent stigma, stereotyping, prejudice and violence
  • accommodate people of different genders
• improve economic and social participation by people of different genders
• promote the right to equality. This is set out in the Charter of Human Rights and Responsibilities and the Convention on the Elimination of All Forms of Discrimination against Women.

Your GEAP will help you meet these goals.

Other benefits of your GEAP

Your GEAP can also:

• improve staff wellbeing – fair and inclusive workplaces boost morale and job satisfaction
• improve organisational performance – gender equality improves innovation, adaptability and productivity
• attract and keep talented staff – gender equality helps you recruit and retain staff
• reduce turnover costs – spend less time and money hiring and training new staff
• future proof your organisation – adapting to social changes keeps your organisation relevant
• reflect the communities you serve – diverse communities deserve a diverse workforce
• enhance your external image and brand – boost your reputation by embracing gender equality.

Organisational change

Your journey towards achieving gender equality is a change process.

Changing established practices, behaviours and systems can be challenging.

It takes leadership commitment, time, persistent effort and resources. However, it will lead to lasting improvements.

Your journey may look different to other organisations (duty holders(opens in a new window)). This is because organisation’s systems, culture, people and processes are different.

How to use the guidance

You do not have to use this guidance. It is an aid to help you develop your GEAP.

You can use all or parts of the guidance. This will depend on what is useful for your organisation.

The guidance takes a step-by-step approach. It walks you through the process of developing your GEAP.

Change management

Your GEAP is about changing your organisation. It aims to create fairer organisational systems.

This includes fairer outcomes for everyone. The process is called change management.

This guidance supports your existing change management approaches. It does not replace them.

Obligations under the Act

If you choose not to use this guidance, refer to GEAP requirements, changes between 2022 and 2026, and key dates(opens in a new window)?

This will help you understand what you must do under the Act.

The steps

Part 1: Preparing to develop your GEAP

Step 1: Planning your GEAP

Step 2: Analysing your data to identify forms of gender inequality

Step 3: Consulting on your audit results (we recommend two rounds of consultation. However, you must undertake at least one round. That is, step 3 and/or step 7).

Part 2: Developing your GEAP

Step 4: Considering the gender equality principles and gender pay equity principles

Step 5: Making a case for change

Step 6: Developing your strategies and measures

Step 7: Consulting on your strategies

Step 8: Resourcing your GEAP

Step 9: Instructions on submission

Part 3: After submitting your GEAP

Step 10: Meeting compliance and the compliance checking process

Step 11: Communicating your GEAP to your organisation

Step 12: Monitoring and evaluation

Step 13: Reporting on your workplace’s gender equality progress and gender impact assessments

There are key roles and responsibilities within your organisation that will help to drive this work. Visit 8.2 Advice on skills needed to develop and implement your GEAP(opens in a new window) and users of the reporting platform(opens in a new window) (including details on how to request access) for a full detailed list.

How to use the template

We strongly encourage you to use the GEAP template. This will help you make sure you include everything required under the Act. Using the template will also make it easier for us to assess your GEAP for compliance.

Required and recommended items

The template includes required and recommended items. You must include all the required items. We encourage you to include recommended items as well.

Information to help you use the GEAP template

At the end of each step, there is a box with information to help you use the GEAP template. Each section in the template includes a link to the relevant section in this guidance.

Word length

We have included suggested word lengths for each section. You are free to go under or over the word length if you have more or less to say.

Template order

The template follows the order of the steps in this GEAP guidance. It aims to reduce inefficiencies and duplication. However, developing a GEAP can be a cyclical process.

You do not have to follow the suggested step-by-step approach. Do what works best in your context. This will vary according to your organisation’s resources, skills and expertise.

For an accessible version of the 2026 GEAP template, please send a request to enquiries@genderequalitycommission.vic.gov.au.

Cover page and attestation

Cover page

The cover page provides important context. It will help us assess your GEAP. The cover page includes:

• organisation name (required) – provide your organisation’s full legal name. Do not use an abbreviated or shorthand version. Include your organisation’s trading name. This is the name you are most well-known by in your industry or publicly
• total number of employees (recommended): insert the total number of employees and full-time equivalent (FTE) roles in your organisation on 30 June 2025
• location (recommended) – insert either metropolitan, regional or rural. Use your organisation’s primary location or your central office. If you insert ‘other’, please explain.

Attestation by head of organisation (required)

The head of your organisation must complete this section. They must state that they have approved your GEAP. They must also state that your organisation will provide adequate resources to implement the GEAP.

Your head of organisation can also use this space to provide further comments for the Commissioner. This is optional.

Your head of organisation is the:

• CEO
• Secretary (for Victorian public service departments)
• Vice-Chancellor (for universities), or
• equivalent.

If you do not use the GEAP template, you must include an attestation in your GEAP.

The attestation must include the following:

I confirm that I am the head of organisation (CEO or equivalent). I confirm I have reviewed and approved the submission of this gender equality action plan (GEAP) on behalf of my organisation (as named), and I attest that the implementation of the GEAP will be adequately resourced.

Sign-off details:

• Name
• Role title
• Signature
• Date of sign-off
• Optional comments from sign-off person

Creating a designed version of your gender equality action plan (GEAP) for publication

You may prefer to create a designed version of your GEAP to publish on your website.

If you choose to do this, you:

• must include all the required sections
• must not alter the wording you submitted to the Commissioner in the required sections (you may fix any spelling or grammatical errors).

Use the GEAP checklist(opens in a new window) to ensure you have all the required sections.

You may:

• reorder the content of your GEAP in your public-facing version to suit your preference
• include additional information not required by the Commissioner.

You may also publish a designed summary and include your completed template as an appendix.

If you decide not to use the GEAP template

If you do not use the GEAP template, make sure it is clear where to find the required components in your GEAP.

Do this by:

• Making a note in the appendix of your GEAP: list all the components that are required under the Act and where to find them in the document.
• AND using clear headings and subheadings that match the sections required under the Act. This will make your GEAP easier for the Commissioner and her team to navigate when assessing for compliance.

Following these instructions will help you demonstrate compliance.

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.

Step 1: Plan your gender equality action plan (GEAP)

This step has recommended actions only.

First, understand your requirements under the Gender Equality Act 2020(opens in a new window) (the Act).

This section also includes a box that provides advice for completing the GEAP template.

1.1 Using insights from your previous gender equality work (recommended)

If you previously completed a GEAP and a progress report(opens in a new window), use the outcomes and reflections to inform your next GEAP.

Consider the following questions:

• What progress did you make towards the 7 workplace gender equality indicators(opens in a new window)?

• What strategies did you complete?
  • What strategies did you not complete, and why?
  • Do these incomplete strategies need to be included in the next GEAP?
  • Did you achieve the outcomes you intended? If not, why?
  • Were there any strategies that were not successful? If so, why?

• Did you have adequate leadership support and commitment from across the organisation? If not, why, and how can you ensure this in your new GEAP?

• What other insights did you gain from implementing your previous GEAP and reporting on your progress?
• Are there other metrics that show success and/or learnings?

• Did you consider intersectional gender equality(opens in a new window)? Are you prepared to do this in your next GEAP?

Use your audit data to inform your GEAP. Also include information you gathered during the required consultation. Consult with employees, employee representatives (unions) and members of your governing body.

Your GEAP must address the aspects of gender inequality you identified in your 2025 audit. These relate to the 7 workplace gender equality indicators(opens in a new window).

1.2 Understand the basics of gender equality (recommended)

Before developing your GEAP, make sure you understand the basics.

This includes:

• What is my duty to promote gender equality(opens in a new window) under the Gender Equality Act 2020?
• What are the gender equality principles, and why do they matter?
• What are the gender pay equity principles, and why do they matter?
• What are the workplace gender equality indicators(opens in a new window)?
• What is intersectionality, and how do you apply it(opens in a new window)?

1.3 Set yourself up for success: processes, record keeping, governance and leadership (recommended)

Before you develop your GEAP, do the groundwork first. This will set your organisation up for success.

Read this guidance and the additional links provided.

Processes

Create a plan to develop your GEAP. The plan outlines the activities and timelines. It also sets out the individuals or teams responsible. A Gantt chart can work well for this.

Your plan keeps you on track to complete everything on time.

Form a working group(opens in a new window) to lead the GEAP development.

Ensure diverse representation. Include different employee equity groups, teams and expertise levels.

Your working group will drive the process, track challenges and ensure progress.

Involve senior leaders. Their support is crucial for the success of your GEAP. The ‘Leadership’ section below provides further guidance on leadership.

Develop a consultation plan. This will outline the steps, resources and time needed for consultation.

State how you will engage staff with diverse experiences.

Set out how you will communicate with employees in existing networks. Document any other channels you will use, such as newsletters and chat groups.

Allow time for feedback and potential delays.

Ensure the process is safe, accessible and respectful for all employees.

Refer to ensure effective consultation and engagement(opens in a new window) for further guidance.

Define key terms like gender equality, intersectionality and the pay gap.

This will help ensure that everyone understands and uses them consistently.

Discuss these terms during the consultation process.

You can also include them in your GEAP in a glossary or definitions section.

Record Keeping

Use good record-keeping practices. Good records will make it easier to:

• track the implementation of your GEAP
• report on progress in future reports to the Commissioner
• evaluate the effectiveness of your GEAP and its strategies.

Governance

You need to have a clear governance structure for your GEAP. This will include lines of authority, accountability and responsibility. Good governance improves:

• accountability
  • clarifying who is responsible for what
  • preventing confusion and inefficiency
• decision making
  • making better organisational decisions
• resource use
  • making sure you have the time, budget and staff to meet your goals
• risk management
  • dealing with issues before they arise.

Leadership

Leaders make a real impact in gender equality. The Champions for Change coalition recommends that leaders:

• communicate the vision – leaders make gender equality a priority. They link this to the organisation’s goals. They promote regular updates and celebrate GEAP achievements. This keeps everyone engaged. Leaders speak openly about gender equality. They show that this work matters
• lead by example – actions speak louder than words. Leaders model inclusive behaviour. They provide strong support for GEAP initiatives. Leaders build trust with employees when they act on their commitments. This encourages others to follow
• set clear priorities – leaders focus on what matters. They dedicate time and resources to GEAP efforts. They ensure gender equality is a priority in their schedules and decision-making
• measure progress – leaders set clear targets, monitor results and hold themselves and others accountable. They motivate teams by recognising and rewarding progress
• engage people managers – leaders ensure that line managers understand their role in achieving the strategies in the GEAP. They also make sure line managers are accountable. Leaders empower line managers to create change. They do this by:
  • setting clear expectations
  • providing support and resources
  • recognising their efforts.

By taking these steps, leaders drive change and create accountability.

They help ensure gender equality is a priority at every level of the organisation.

The GEAP template provides space for you to reflect on the issues above. You can also include a statement from the head of your organisation about their commitment to gender equality.

1.4 Learn from other organisations

Sharing knowledge about gender equality with other organisations is a great way to source ideas. It also helps you see what others in your sector are doing.

You can do this by:

• joining communities of practice – these communities connect you with others working on gender equality
• exploring the insights portal to review 2021 GEAPs and progress submitted by similar organisations. This can help you find relevant, practical ideas, strategies and approaches
• connect with other duty holders to learn about their experiences firsthand.

How-to guides

• Creating a working group(opens in a new window) to help develop and implement your GEAP
• Gaining leadership commitment

Further reading

• Power to create inclusive gender equality in the workplace(opens in a new window) (Champions of Change coalition)
• Discussion guide on power to create inclusive gender equality in the workplace(opens in a new window) (Champions of Change coalition)
• The Leadership Shadow (understanding and using your leadership influence(opens in a new window)) (Champions of Change coalition)
• (En)countering resistance: strategies to respond to resistance to gender equality initiatives(opens in a new window) (VicHealth)
• Avoiding the merit trap(opens in a new window) (Champions of Change)
• Workplace equality and respect standards(opens in a new window) (Our Watch)
• Workplace equality and respect: how-to guide(opens in a new window) (Our Watch)
• Workplace positive duty standards(opens in a new window) (Our Watch)
• Inclusive workplace toolkit: understanding different kinds of discrimination(opens in a new window) (Hue Colour the Conversation)
• Gender affirmation in Victorian public sector workplaces(opens in a new window) (Victorian Public Sector Commission)
• Transgender people at work(opens in a new window) (Victorian Equal Opportunity and Human Rights Commission)
• The Man Box: the attitudes and behaviours of Australian manhood(opens in a new window) (Jesuit Social Services)

Analyse your 2025 workplace gender audit data. This helps you understand the gender inequalities in your organisation.

View the Analysing your workplace gender audit results(opens in a new window) guidance note for more on this topic.

2.1 Include the results of your audit in your GEAP (required)

Include the results and analysis of your workplace gender audit in your GEAP. Some ways of including this audit data are:

• provide data against each workplace gender equality indicator (refer to ‘Completing the GEAP template’ box at the end of this step)
• explain the outcomes of your analysis (refer to the ‘Completing the GEAP template’ box at the end of this step).

You could also:

• include a more detailed analysis of your data. Use the space at the end of the GEAP template (or an appendix, if you choose not to use the template)
• use infographics, summaries and graphs. You can add an appendix or add more to the ‘Any other additions or comment’ (optional) if you choose not to use the template.

Refer to the 2025 audit guidanc(opens in a new window)e for instructions on collecting and submitting your audit data.

Upload your audit data to the reporting platform(opens in a new window). Use the reports on the reporting platform to help you analyse the data.

Using the performance measures

We encourage you to provide audit data for the performance measures for each indicator.

These measures set out the minimum expectations for this data.

We chose them because:

• they provide the minimum data you need to get started
• they help you focus on the most important data
• they are simple and easy to talk your stakeholders about
• you already collect this data as part of your audit.

Using the performance measures helps you see connections. It will also help you drive and assess progress.

If you do not use the performance measures

You do not have to use the performance measures in your GEAP. You can include different data from your audit.

However, the measures are practical and represent benchmark data.

If your organisation is more progressed in its gender equality journey, you can use your own data as well as the performance measures.

You may provide alternative data to the performance measures. The Commissioner will determine whether this is appropriate and adequate. Refer to the guide on how to analyse your data.

Your organisation may not have data against all the performance measures from 2023 and 2025. This will not impact your compliance.

If you do not currently collect data against one or more of the performance measures, consider a strategy to collect this data in future.

For further guidance on how to use the performance measures to evaluate the success (or not) of your strategies, refer to 6.2 Setting measures(opens in a new window).

About the performance measures

There are 2 types of measures.

The first is critical measures. These are minimum measures.

These are considered the minimum data to understand gender inequality in your organisation.

You can achieve compliance without providing data against them. However, the Commissioner prefers that you use these measures.

The second is supplementary measures. These are recommended for duty holders with capacity for further analysis.

Providing data against supplementary measures helps you understand gender inequality issues in your organisation.

To view the performance measures in full, visit Performance Measures.(opens in a new window)

2.2 Identify underlying causes of inequality in your organisation (recommended)

Your audit data will reveal any inequalities based on gender (and possibly other forms of discrimination).

However, it will not explain why or how those inequalities came about.

Understanding the root causes of inequalities is vital to help develop practical solutions.

The following steps will help you understand what is behind any inequalities revealed in your data.

Clarify the problem

Start by identifying inequalities in relation to the workplace gender equality indicators in the Act. Some questions to think about include:

• What is the workforce and employee experience data telling me?
• What further data or evidence do we have on these issues?
• What gaps or discrepancies are there in the data?
• What do I know about the problems? What don’t I know about the problems?
• How does the problem impact those who may experience intersecting disadvantages?

Analyse the problem

Investigate the root causes of problems. This helps you understand why these problems exist.

It ensures your strategies address the underlying causes, not just the symptoms.

Consider how organisational culture, policies and practices contribute to workplace gender inequality. Examine any inequalities that you find against the workplace gender equality indicators.

Consider:

• Why does the problem exist? What are the causes of gender and other inequalities?
  • To understand the gender pay gap, check if your organisation has jobs done mainly by one gender. For example: Most machine operators are men. They earn more than the administrative staff, who are mostly women and gender-diverse people. This could explain part of your pay gap. Gender segregation might be a reason for the gender pay gap.

If possible, consider which groups experience the problem more or differently. This includes Aboriginal women, women with disabilities, culturally and linguistically diverse (CALD) women, trans men et cetera.

• How are people affected by the problem?
• How do existing organisational policies, practices and culture contribute to the problem?
• How do external factors influence the problem?
• Why have previous efforts to address these inequalities not been successful?
• What needs to change?
• What additional information or data do we need to better understand these problems?
• How do employee perceptions and experiences align with our data?

Some of these questions are best asked during your consultation (refer to step 3(opens in a new window)).

However, it is helpful to research them first. You can then test your findings during consultation.

The Commissioner’s Baseline report: 2021 workplace gender audit data analysis(opens in a new window) has further information on each of the indicators.

Problem statement

Create problem statements related to each workplace gender equality indicator. Problem statements create a shared understanding of the problems.

First, analyse your audit data. Then, include a problem statement to summarise your analysis. This is usually one or two sentences long, using plain language.

Example problem statements:

• Gender pay equity: The gender pay gap hinders gender equality in our workplace. Women earn, on average, $12,000 a year less than men. This gap is because women are concentrated in lower levels of our organisation and in lower paid areas. Unconscious bias may also play a role, as women in our organisation are not being trained and promoted equally.
• Gendered segregation: Gendered segregation in our workplace remains a critical issue. Women hold 85% of administrative roles. Men hold 90% of engineering and maintenance roles. Administrative roles pay, on average, less then engineering roles. This imbalance reinforces gendered stereotypes. This contributes to our gender pay gap and limits diversity in decision making.

Prioritise problems to address

Your analysis may have revealed lots of problems.

Prioritise the biggest issues for each of the workplace gender equality indicators(opens in a new window).

Make sure you understand the root causes of the problems.

Under the Act, you must be able to demonstrate reasonable and material progress in addressing at least some aspects of inequality on each of the indicators in each 2-year period (if your data shows that inequality exists).

Some questions to think about in prioritising problems to address include:

• Which problems have the most impact on our employees and organisation?
• What problems are most urgent and require immediate attention?
• Which problems, if resolved, would lead to the most impactful and sustainable change?
• How do these problems intersect with our vision, goals, and stakeholders' expectations?
• How do these problems intersect with the gender equality principles and the gender pay equity principles?

Completing the GEAP template

Instructions for the template that relate to this step can be found in step 6. This is due to how the template is designed.

Please refer to step 6(opens in a new window) for further guidance.

How-to guides

• Using a range of data sources to inform your GEAP development
• Highlighting where data gaps currently exist and your plan for building data collection
• Using intersectional analysis to understand data
• Outlining key insights from applying an analysis of intersectional gender inequality
• Outlining any other information sources or data that were considered as part of your GEAP development
• How to maintain employees’ privacy(opens in a new window)

Further reading

• Unpacking intersectional approaches to data(opens in a new window) (Global Partnership for Sustainable Development Data)
• The ‘but why?’ technique(opens in a new window) (Community Toolbox)

You must undertake at least one round of consultation. Step 7(opens in a new window) is the other opportunity to meet this requirement.

It is up to you how you consult stakeholders. We recommend you undertake 2 rounds of consultation. This includes consulting on your audit results and on your strategies (refer to step 7(opens in a new window)).

3.1 Consult on your audit results

Consultation helps make employees and stakeholders aware of your workplace gender audit findings. It also provides the opportunity to discuss the impact and possible actions for change. This helps you determine, and prioritise, actions to address issues. Employees from diverse backgrounds may be able to provide valuable insights into barriers to gender equality they experience.

If there are existing ways to consult under enterprise agreements and other laws (like the Occupational Health and Safety Act 2004), use them in your GEAP consultation process. Partner with those involved to enhance them if needed (see below).

Consultation and engagement require careful planning. This includes:

• deciding the purpose of your consultation
• identifying who to consult
• advice on specific stakeholders:
  • consulting with union representatives
  • consulting with your governing body
  • involving senior leaders
• managing effective consultation and engagement, including:
  • consultation methods
  • budget and timeframe
  • communication methods
  • choosing who to lead the consultation
  • supporting participants to feel safe
  • consultation materials
  • documenting and sharing consultation feedback
  • intersectional approach to engagement
• gathering feedback and reflections on your consultation process.

How-to guides

• Consulting with union representatives
• Consulting with your governing body
• Step 10: Meeting compliance and the compliance checking process(opens in a new window)
• Participatory approaches(opens in a new window) – accessible for all Victorian public sector employees.

Step 4: Consider the gender equality and the gender pay equity principles, and intersectionality

This step includes required and recommended actions.

You must consider:

• the gender equality principles (as required under the Gender Equality Act 2020)
• the gender pay equity principles (as required under the Gender Equality Regulations 2020).

You must also take intersectionality into account, where practicable.

This step provides guidance on:

• 4.1 Consider the gender equality principles (required)
• 4.2 Consider the gender pay equity principles (required)
• 4.3 Consider intersectional gender equality (required)

This section also includes a box that provides advice for completing the GEAP template.

4.1 Consider the gender equality principles (required)

You must explain how you have taken the gender equality principles into account in your GEAP.

Simply listing the principles and stating that you have taken them into account is not enough.

Some ways you can demonstrate you have considered the gender equality principles include:

• Building the case for change – use the principles to explain why gender equality matters your organisation, the sector and the community. Show how they relate to your workplace. Provide evidence
• Defining your GEAP’s vision and objectives – use the principles to put forward your GEAP’s vision and goals. Draw on the principles for language or inspiration
• use the principles to start discussions during consultations – ask staff what the principles mean to them. Use the principles to guide talks about audit data, issues or strategies
• use the principles to choose and prioritise strategies – they can inform your decision making
• engage your leadership team via the principles – educate leaders on gender equality
• develop a monitoring and evaluation framework – measure progress against your strategies and measures. Use the principles as goals
• collaborate with similar organisations – work with other organisations that share these principles to deliver initiatives.

4.2 Consider the gender pay equity principles (required)

You must consider the gender pay equity principles in your GEAP.

This is a new requirement under the Gender Equality Regulations 2020.

You must explain how you have taken the gender pay equity principles into account. Again, simply listing the principles and stating that you have taken them into account is not enough.

To learn more about the gender pay gap, refer to KPMG’s She’s Price(d)less 2022 report. This report looks at what drives the gender pay gap. It explains why the pay gap exists. It sets out the priorities for fixing it.

Some ways you can demonstrate how you have considered the principles include the following:

Analysing your audit data

• Look at pay differences between employees. Break these down by gender. Consider intersectionality (if you have this data).
• Compare the pay of people of different genders at the same level.
• Analyse gender and demographic trends related to alternative working arrangements. This includes unpaid and caring work.
• Examine how your organisation responds to requests for different part-time and flexible work arrangements at senior levels.

Planning your consultation process

• Share gender pay gap data with your employees. Consider intersectionality (if you have this data).
• During consultation, discuss:
  • recruitment, promotion and training processes
  • pay practices like base salaries, salary packages, bonuses and loadings
  • how these practices affect different groups
  • ways to make these processes fairer.
• Describe how your consultation collectively designed gender pay equity solutions (principle E).
• Describe how you used the principles in consultation to support collaboration between employees, unions, and your organisation (principle F).

Considering your organisational values

• Discuss how the gender pay equity principles align with your organisational values. These might include transparency, collaboration, and freedom from bias and discrimination.
• Refer to any gender pay equity principles in your enterprise agreements.

Develop strategies on gender pay equity

• Use the principles, audit findings and consultations to inform your strategies. You can do this across multiple relevant indicators. These include flexible work, leave, recruitment, promotion and development.
  • For example, more women than men work part-time. This can limit their access to senior roles, which are usually full-time. This can widen the gender pay gap. Policies that support part-time/job-share at senior levels can improve gender pay equity.
• Address as many principles in your strategies as possible.
• Review your pay and promotion policies. See whether they reflect the gender pay equity principles.

Refer to the strategies on the gender pay equity principles for more information on developing strategies using the gender pay equity principles.

4.3 Consider intersectional gender equality (required)The Act requires duty holders to consider intersectional gender inequality.

Intersectional gender inequality is the disadvantage or discrimination on characteristics that a person may experience on the basis of any of the following in addition to gender

• Aboriginality
• age
• disability
• ethnicity
• gender identity
• race
• religion
• sexual orientation.

Refer to Applying intersectionality to the gender pay equity principles in step 4.2 for examples of using intersectional analysis.

You must take intersectionality into account when preparing your GEAP.³

Explain how you have considered it in section 9 of the template.

If possible, collect demographic attribute data about your workforce. Use this data to examine the intersections between gender inequality and other forms of discrimination or disadvantage. Consider this in relation to the workplace gender equality indicators(opens in a new window).⁴

An intersectional approach helps you develop better policies and processes for all employees.

Refer to our Applying intersectionality guide(opens in a new window) to learn how to apply an intersectional approach in your GEAP.

References and Footnotes

3. Where possible, consider intersectionality when you undertake your gender impact assessments. Provide data about attributes beyond gender in your audit if possible.

4. Note that methods for applying an intersectional lens to quantitative data are still being developed (Ben 2018). As such, there is no single, correct way to undertake an intersectional analysis of your workforce and employee experience data (source: intersectional guide).

A case for change involves explaining why gender equality matters at your workplace.

5.1 Develop a case for change (recommended)

Include a case for change. This explains why gender equality is important for your workplace.

The case for change is mainly for your workforce.

However, it also explains to the wider community why gender equality matters(opens in a new window) for your organisation.

It is a useful communication tool. It can help employees understand why your GEAP matters.

Your GEAP:

• promotes, encourages and facilitates gender equality and improvement in the status of women
• supports the identification and elimination of systemic causes of gender inequality. This includes in policy, programs and services in workplaces and communities
• recognises that gender inequality may be compounded by other forms of disadvantage or discrimination. This includes Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and other attributes
• addresses disadvantage, stigma, stereotypes, prejudice and violence. It can help create the structural change you need to accommodate different genders
• improves economic and social participation
• promotes the right to equality set out in the Charter of Human Rights and Responsibilities and the Convention on the Elimination of All Forms of Discrimination against Women.⁵

Additionally, acting on gender equality can also:

• improve the wellbeing of staff
• enhance your organisation’s external image
• improve your organisation’s competitiveness
• help your organisation attract and retain talented staff
• reduce costs associated with staff turnover
• enhance productivity
• help future-proof your organisation.

In your case for change, you can address the underlying causes of gender inequalities at your organisation (refer to step 2(opens in a new window)). You can explain how you will commit to changing these.

You can also include your organisation’s commitment to the gender equality principles and the gender pay equity principles. You can state how these have informed your strategies to promote gender equality(opens in a new window) in your organisation.

5.2 Creating a vision (recommended)

As part of your case for change, you could also include a vision.

A vision statement expresses your organisation’s long-term goal for gender equality.

A strong vision can help to align efforts, energise stakeholders and create unity.

It helps everyone understand what they are working towards. This can help drive the success of your GEAP.

Ideally, your vision will be:

• led by employees – work with staff from diverse lived experiences to create a vision. This promotes ownership of the vision. Consider describing how employees helped shape the vision in your GEAP
• easy to understand – use simple language so stakeholders can easily grasp it
• impactful – describe the intended impact in your workplace and its significance for the community.

How-to guides

• Acknowledging your existing efforts on gender equality
• Aligning with other equality commitments relating to Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and other

Further reading

• What is intersectionality?
• WGEA’s workplace gender equality: the business case(opens in a new window) (WGEA)
• A guide for inclusive gender equality by design(opens in a new window) (Champions of Change Coalition)
• Inclusive workplace toolkit – understanding different kinds of discrimination(opens in a new window) (Hue Colour the Conversation)
• Workplace equality and respect standards and how to guide(opens in a new window) (Our Watch)
• Workplace positive duty standards(opens in a new window) (Our Watch)

Footnote

5. Objects of the Act (7)

You must develop strategies and measures. You must document these in your GEAP.

Your strategies are the actions your organisation will take. They aim to improve gender inequalities. Strategies must address the 7 workplace gender equality indicators(opens in a new window) (and any other areas of gender inequality you identify).

Your measures assess the performance of your strategies. They show you how well your strategies are working. They help you see where you need to make changes to keep your GEAP on track.

6.1 How to develop your strategies (recommended)

Your strategies should:

• address gender inequality on each of the 7 workplace gender equality indicators(opens in a new window). They will be for the lifecycle of your GEAP
• be specific, measurable, achievable, relevant and time-bound (SMART).⁶
• target the underlying causes of gender inequality in your organisation (refer to step 2.2).
• use an intersectional approach(opens in a new window) where possible. This will help you address any compounding forms of discrimination impacting your employees. It will make your gender equality strategies inclusive and targeted.

How many strategies

You must have at least one strategy for each indicator.

If you are performing well on an indicator, you should choose a maintenance strategy that will maintain your positive outcomes.

For example, your governing body may already have a balanced gender composition (indicator 2). A maintenance strategy would include an action that any change to the governing body will trigger a review of its gender composition to ensure it remains balanced.

Strategies with intersectional focus

Include strategies that address different experiences of inequality for different groups of people.

For example, you may have a balanced gender composition of the governing body (indicator 2). However, the governing body may not represent the diversity of the community you serve. Consider including strategies to improve this.

We suggest you use the following steps to develop your strategies:

Understand the underlying problems (refer to step 2(opens in a new window))

• Analyse your workforce and employee experience data. Look at patterns and issues on the 7 workplace gender equality indicators.
• Conduct additional research if needed. Use surveys, interviews, or review existing studies to understand the problems better.
• Identify the underlying issues. Find the root causes of gender inequality in your organisation (refer to step 2.2).

Consult with staff about your audit results (and any other research) (refer to step 3(opens in a new window))

• Engage with employees and employee representatives. Talk to your staff to understand deeper issues related to gender inequality. Their insights can help identify root causes (refer to step 3).

Refer to your vision and principles

• Use your vision and the gender equality principles and gender pay equity principles to frame where you want to go. These help you make decisions and stay focused on your goals (refer to step 4).

Plan where you want to go by assessing current state and desired future state

• Clearly define where your organisation is now, and where you want it to be in 4 years’ time (at the end of the lifecycle of your GEAP). Refer to WGEA’s policy and strategy guides(opens in a new window) for further guidance. Step 6.2 provides information on setting targets.
• Outline the steps to move from the current state to the future state.
• Decide what success will look like for your organisation. Ensure you can measure this.

Learn from others

• Review other GEAPs and progress reports on the Commission’s reporting platform(opens in a new window). Look at what other organisations have done. Seek further advice from them (refer to step 1.4).
• Review research and evidence. Use strategies that have worked in similar contexts. For instance, refer to the Workplace Gender Equality Agency’s Employer of choice for gender equality: leading practices in strategy, policy and implementation(opens in a new window).
• Determine feasibility. Consider the strategies that worked in other contexts. Ask yourself whether the strategy is:
  • appropriate – does it fit my purpose?
  • replicable – is there enough detail about the strategy and its outcomes to replicate it?
  • practical – is it feasible to implement this in my organisation?
  • compatible – is the intervention appropriate for my organisation’s situation?

Develop strategies

• Choose comprehensive strategies. Consider all parts of your organisation, like structure, culture, policies and practices.
• Consider how these parts are connected. Strategies could focus on:
  • addressing any data gaps you have in your workplace gender equality audit
  • policies and processes
  • communication and engagement
  • education and training
  • culture change
  • leadership and accountability.
• Ensure strategy options address intersectional gender inequality if possible.

Workplace Gender Equality Agency resources

Visit the Workplace Gender Equality Agency’s policy and strategy guides(opens in a new window) for further guidance on:

• Equal remuneration between women and men(opens in a new window)
• Gender composition of the workforce(opens in a new window)
• Gender composition of governing bodies(opens in a new window)
• Flexible working arrangements(opens in a new window)
• Sexual harassment, harassment on the ground of sex and discrimination(opens in a new window)
• Strategies and setting targets for gender diversity(opens in a new window)

6.2 Set measures (required)

You must consider how your GEAP will help your organisation make measurable progress on each of the 7 workplace gender equality indicators(opens in a new window).

Measures will help your organisation:

• assess how your strategies are performing
• monitor the outcome and implementation of your strategies
• your progress towards gender equality
• track progress towards specific targets (refer to 6.3 Setting targets).

Performance measures

The performance measures will be used to assess your future progress against the indicators. They set out the minimum expectations for each indicator.

We strongly encourage you to use the performance measures developed by the Commissioner and her team. They will help you to understand your progress on each indicator. The table below sets out these measures. They also appear in the Guide on how to analyse your data.

The performance measures are outcome measures. Outcome measures show whether your strategies achieved your targets.

You might also want to consider using process measures. Process measures determine how well you implemented your strategies.

Using both types of measures helps you to understand what worked and what did not work with your strategies. It also helps you understand whether their success (or not) was because of the desired effect of your strategies (i.e. outcomes) and/or their implementation (i.e. process).

They can also help you explain your findings to the Commissioner and key stakeholders.⁷

Why did the Commissioner and team choose these performance measures?

We chose them because:

• they are the minimum data points needed to determine whether your strategies are working. They help you understand where to start
• they help you focus on the most important measures
• they are simple and straightforward measures that are easy to talk about with your stakeholders
• you already collect data on the measures as part of your audit. Therefore, there is no extra work to use the measures
• they support you and your stakeholders to see connections between these obligations.

You do not have to use the performance measures. However, the measures are practical and provide a benchmark to measuring change.

You can use your own measures in addition to the performance measures.

Your organisation may not have data against all the performance measures from 2023 and 2025. This will not impact your compliance.

If you do not currently collect data against one or more of the performance measures, consider a strategy to collect this data in future.

What are the two types of outcome performance measures?

There are 2 types of measures:

• Critical measures are the minimum measures. These are the benchmark for your progress. You may achieve compliance without using them. However, the Commissioner wants you to use these measures
• Supplementary measures are recommended for duty holders. Use the supplementary measures to better understand and assess gender inequality issues in your organisation.

The performance measures are pre-filled in the GEAP template.

These measures are the minimum expectations for your GEAP.

How will the performance measures be used?

The Commissioner will use the measures to assess your progress in 2 years’ time.

You can use additional measures if you are more progressed in your gender equality journey.

If you do not use the performance measures developed by the Commissioner, the Commissioner will determine whether the alternative measures you use are appropriate and adequate.

Refer to the guide on how to analyse your data.

6.3 Setting targets (recommended)

Targets help you make progress on the indicators.

They are the measurable change or outcome you seek.

Setting targets helps:

• focus your efforts
• indicate whether your strategies are on track
• decide if you need to change your strategies.

Targets should be:

• aspirational but achievable
• measurable
• time-bound
• related to outcomes.

To set targets you should:

• use your current audit data as a baseline to monitor, compare and assess progress. This can also help to determine whether your targets are realistic.
• describe the direction you want to achieve. This includes ‘to reduce’ or ‘to improve’.
• reflect the final state, not the change needed to get there.

Use the format: ‘By when, who/what will experience what type of change, by how much’.⁸

For example:

• Your audit data identifies a problem: ‘In 2025, the pay gap between men and women, was 10.0% in favour of men (mean total remuneration)’.
• The target could be: ‘By 2030, our pay gap between men and women will have reduced by 50%’.

For further guidance on setting gender equality targets, visit:

• Guide to setting gender targets(opens in a new window)
• Target setting for gender equality: a review of the literature(opens in a new window)
• What works, what’s fair(opens in a new window) (promoting workplace gender equality)
• Employer of choice for gender equality: leading practices in strategy, policy and implementation(opens in a new window)

6.4 Documenting your strategies and measures (required)

You must include at least one strategy per indicator.

Using the template

Use the GEAP template to document your strategies and measures.

This section of the template is organised by the 7 workplace gender equality indicators(opens in a new window).

An additional table is provided for strategies that fall outside of the indicators.

If you choose not to use the GEAP template, you must include strategies and measures for promoting gender equality in the workplace.

These should be based on the results of the workplace gender audit(opens in a new window). You should group them by the workplace gender equality indicators(opens in a new window). This will help us to assess compliance of your GEAP.

If your organisation does not have a governing body

If your organisation does not have a governing body, you do not need a strategy for this indicator. Please state this in your GEAP.

If you have not identified a gender equality problem for an indicator

If you have not identified a gender equality problem for one or more of the indicators, you should still include a maintenance strategy. This makes sure you do not lose what has been achieved.

For example, your governing body may already be gender balanced and diverse. In this instance, you could include a strategy to monitor its composition. This could be at regular intervals or points of turnover. This is called a maintenance strategy.

In addition, you could include a strategy to build the capacity of the governing body to lead on gender equality. This is called an extension strategy.

How-to guides

• Developing strategies using a comprehensive approach, including strategies on:
  • policies and processes
  • communication and engagement
  • education
  • data gaps and measuring change
  • gender pay equity principles
• Applying an intersectional lens to your strategies and measures
• Prioritising your strategies with low resourcing

Further reading

• Accelerating workplace gender equality toolkit(opens in a new window) (Gender Works)
• Breaking dad psychological safety and men’s parental leav(opens in a new window)e (the 100% project)
• Employment and disability in Australia: Improving employment outcomes for people with disability (opens in a new window)(Bankwest Curtin Economics Centre)
• Recruit smarter: Inclusive recruitment practices and addressing unconscious bias in recruitment(opens in a new window) (Victorian Government)
• National review into work conditions and discrimination among pregnant and parent workers in Australia(opens in a new window) (University of South Australia)
• Strategies and policies on 6 gender equality indicators (opens in a new window)(Workplace Gender Equality Agency)
• Building respectful and inclusive workplaces: men’s positive roles in violence prevention(opens in a new window) (XY online)
• Intersections at work: understanding the experiences of culturally diverse LGBTQ talent(opens in a new window) (Diversity Council Australia)
• Encountering resistance: strategies to respond to resistance to gender equality initiatives(opens in a new window) (VicHealth)
• Avoiding the merit trap(opens in a new window) (Champions of Change)

Footnote

7. Issel (2013) Health program planning and evaluation: a practical, systematic approach for community health, Jones & Bartlett Learning, USA.

8. Issel (2013) Health Program planning and evaluation: a practical, systematic approach for community health. Jones & Bartlett Learning, USA.

The Act requires you to do at least one round of consultation. You need to consult with employees, employee representatives and your governing body.

It is your choice how you undertake the consultation.

We recommend two rounds of consultation: one in relation to your audit results (refer to step 3(opens in a new window)) and one in relation to your strategies and measures.

7.1 Consulting on your strategies (recommended)

After drafting your strategies, gather feedback on them.

Do this by consulting with employees, union representatives, any other employee representatives and members of your governing body (if you have one).

Do this before you finalise your strategies.

The consultation process can reveal gaps, challenges and areas for improvement.

Consultation helps to ensure the strategies are practical, relevant and supported by stakeholders.

Some questions to ask during consultation include:

• reflect on previous GEAP and progress reports (if relevant) – what worked and did not work?
• clarity – are strategies clear and easy to understand?
• relevance – do the strategies cover the main gender inequality issues in our organisation?
• feasibility – are the strategies realistic within the timeframe?
• impact – do you think the strategies will have the desired impact on the workplace gender equality indicators?
• missing groups – are there groups in our organisation whose experiences of gender equality are not accounted for in these strategies?
• lived experience – are strategies meaningful to diverse employees, especially those potentially experiencing discrimination?
• involvement – what would help stakeholders feel more engaged in the GEAP?

This step complements step 3: consult on your audit(opens in a new window). For further guidance on how to plan and run consultations, see:

• Deciding the purpose of your consultation
• Identifying who to consult
• Advice on specific stakeholders:
  • consulting with union representatives
  • consulting with your governing body
  • involving senior leaders
• Involving senior leaders
• Managing effective consultation and engagement, including:
  • consultation methods
  • budget and timeframe
  • communication methods
  • choosing who to lead the consultation
  • supporting participants to feel safe
  • consultation materials
  • documenting and sharing consultation feedback
  • intersectional approach to engagement
• Gathering feedback and reflections on your consultation process

7.2 Documenting your consultation (required)

State how you consulted (at least once) with your employees, union representatives, any other employee representatives, and members of your governing body (if you have one).

This might include:

• consultation methods, such as online, in-person, through surveys or focus groups
• how the consultation shaped the interpretation of audit results, development of strategies and measures and other aspects of your GEAP
• participant numbers for each stakeholder group
• how you created an inclusive and safe consultation
• communication methods such as using infographics to make information easy to read and understand.

You can include extra details about the consultation in the section at the end of the GEAP template for additional comments. This keeps the main body of the GEAP concise.

If you choose not to use the template, you can include this information in an appendix.

Completing the GEAP template

This step aligns with the advice in step 3. Refer to step 3 for guidance on completing the GEAP template.

The Act requires you to allocate adequate resources to developing and implementing your GEAP.

You must provide evidence of adequate resources to implement your GEAP strategies.

This includes making reasonable and material progress on each of the workplace gender equality indicators(opens in a new window) in every 2-year period (required).

The head of your organisation must attest on the GEAP cover page that the resourcing is adequate to implement the GEAP.

Responsibility for your GEAP may sit across multiple functions of your organisation. It should have strong leadership support.

8.1 Develop a plan that show how your GEAP will be resourced (recommended)

You must demonstrate that your organisation has allocated adequate resources to:

• developing the GEAP
• implementing GEAP strategies.

This is required.

Providing adequate resources ensures you can make reasonable and material progress on each of the workplace gender equality indicators(opens in a new window) over the 4-year lifespan of your GEAP.

Use the GEAP template to document your:

• resourcing needs assessment
• resourcing gaps
• resource allocation.

You may want to use a more detailed resourcing plan than the one we provide in the template.

Steps to build your resourcing plan

Recommended steps to building your resourcing plan include the following:

Identify current and required resources

Identify the resources you need to implement each strategy.

This might include human, financial, technological, physical and time resources.

Assess the resources you currently have or have access to. Compare this to your resourcing needs against each strategy to identify your resource gap.

Consider how you can:

• allocate resources across different parts of the organisation – if you are part of a larger organisation, GEAP work may involve multiple teams. Ensure all teams have the resources they need to do their work successfully
• look for shared resources – determine if GEAP actions are new or if they overlap with other ongoing work. Consider sharing resources from other projects if they overlap
• plan for ongoing engagement – allocate time and budget for staff engagement and consultation throughout the GEAP lifecycle
• budget for evaluation and communications – set aside resources for monitoring and reporting. Ensure adequate resources are allocated for these tasks, including staff time, systems or training
• join or form communities of practice and collaboration – including sharing tools/toolkits, knowledge or resources with other organisations
• investing in systems and processes – invest in systems and processes to streamline your future gender equality work. This could include upgrading or investing in human resource information management systems, project management software or developing monitoring and evaluation tools such as data dashboards. It could also involve designing processes for developing this GEAP that can be repeated for future GEAPs to reduce workload.
• outsourcing – consider whether outsourcing or using temporary contracts is right for your organisation. Outsourcing can create loss of knowledge over time. This can mean more work in future.

Develop a resourcing plan

Your resourcing plan could include:

• matching resources to specific strategies and measures
• a timeline showing when each resource is needed
• identifying any dependencies (such as tasks that cannot start until a specific resource is available)
• dates for regular review and adjustment of the plan to ensure resources are adequate to achieve the outcomes.

8.2 Advice on skills needed to develop and implement your GEAP (recommended)

The following list of skills are a suggested minimum:

• project management / change management / improvement skills
• consultation skills
• communication skills
• data collection and analysis skills
• leadership skills
• technical skills (desirable), including:
  • gender equality and intersectional knowledge. Not having this knowledge will not put you at a disadvantage. If you do not have access to this skill, talk to your sector colleagues or join a community of practice(opens in a new window)
  • research skills to help you gain evidence-based knowledge of the underlying causes of inequality. Not having access to this skill will not put you at a disadvantage
  • basic IT skills to use the reporting platform, guidance and templates. The ability to track and monitor your progress through applications (like Sharepoint) will be advantageous.

How-to guides

• Prioritising your strategies(opens in a new window)

Submission

It is highly recommended that you submit using the GEAP template 2026 via the reporting platform(opens in a new window)*. Note that supporting documents will not be accepted.

If you choose not to use the GEAP template 2026 (not recommended), ensure you have included all the required components in your GEAP and have a table of contents that shows the Commissioner and her team exactly where to find them.

Request an extension

If you experience unforeseen circumstances that will impact whether you can complete your GEAP on time, you can request an extension to submit your GEAP. Should you need this, send a request to the Commissioner as soon as possible before the submission date. For further information on extension requests, visit Commissioner's extension request page(opens in a new window).

Note that any extension will not change your future obligation deadlines under the Gender Equality Act 2020(opens in a new window).

Reporting platform

Your reporting process owner and platform users have access to the reporting platform.

To request access for new reporting platform users, fill this Nomination of Gender Equality Act(opens in a new window) reporting platform users(opens in a new window) form. Note that only reporting process owners or your head of organisation can complete this form.

If you have questions about how to use this form, please contact the Commissioner’s team via enquiries@genderequalitycommission.vic.gov.au

Did you include the following required components?

The results of your workplace gender audit(opens in a new window) to identify forms of gender inequality for each of the 7 workplace gender equality indicators.

Details of at least one round of consultation (opens in a new window)with your governing body, employees, employee representatives and any other relevant people to develop your GEAP.

A description of how you considered the gender equality principles, and the gender pay equity principles.

Consideration of intersectionality, where practicable.

Strategies for each of the seven indicators.

Measures for each of the seven indicators.

A description of how your GEAP implementation will be adequately resourced(opens in a new window).

Attestation (opens in a new window)(sign off) by your head of organisation.

Step 10: Meeting compliance and the compliance checking process

After you submit your GEAP, it will be reviewed for compliance.

Compliance review is a rigorous, multistage process. It ensures fairness and thoroughness.

We appreciate your patience during the compliance review process.

We will provide updates on the status of the compliance review through our newsletters and direct email communications.

Meeting compliance (assessment rubric)

The compliance assessment rubric will be published here in the second half of 2025.

Compliance checking process

Your GEAP will be assessed for compliance under section 10 of the Gender Equality Act 2020.

Your GEAP will be assessed against a compliance rubric.⁹

If you submitted your GEAP via the platform, you will receive a notification when your GEAP status changes to ‘checking for compliance’.

Your compliance outcomes will be sent to your reporting process owner (RPO), your CEO (or equivalent) and your board Chair (if you have one) at the same time.

Feedback and next steps

After the compliance review, we will tell you whether your GEAP meets compliance requirements. Feedback will include:

• whether your GEAP is compliant
• a compliance outcome against each of the compliance criteria
• requirement to resubmit (within a specified timeframe) if compliance issues are identified
• further information on next steps.

What you can do while you wait for feedback

Start implementing your GEAP strategies. Do not wait for your compliance outcome.

Keep your team informed about the process and next steps.

Develop materials to announce and explain the GEAP to your organisation.

Keep up your gender impact assessments(opens in a new window) (GIA).

Footnotes

9. This will be published in the third quarter of 2025.

Understanding what to expect after submitting your GEAP prepares you for any feedback or revisions. The Act requires that you:

(a) publish your GEAP on your website within a reasonable time after submitting it to the Commissioner

(b) notify your governing body, employees and employee representatives of the publication.

You can wait to publish your GEAP after it has been assessed for compliance by the Commissioner.

The Commissioner expects you (as a duty holder(opens in a new window)) to publish your GEAP on your website within 3 months of receiving a compliance outcome.

11.1 Publish your GEAP on your website (required)

You must publish your GEAP on your public website.

Publishing your GEAP on your website shows your commitment to gender equality to your staff and stakeholders.

It also ensures you are accountable to your employees and the community.

When to publish

• You must publish your GEAP within a reasonable time (3 months) after you receive your compliance outcome.
• If you publish your GEAP before it is checked for compliance, you may need to make updates to the published version. If you publish early, please include a disclaimer noting that the GEAP:
  • has not been checked for compliance by the Commissioner
  • may be subject to change.

Publishing format

• You can choose to publish your GEAP in the following formats:
  • the format provided by the Commissioner (the template)
  • an alternative format (for example, graphic designed).
• Important: you must remove any personal or potentially identifying information(opens in a new window) before publishing your GEAP.
• If you reformat your GEAP, you must include all 'required' sections of the GEAP.
• If you publish a designed version of your GEAP you must:
  • include all the required sections in the designed version.
  • not alter the wording you submitted to the Commissioner in the required sections (you may fix any spelling or grammatical errors).

The Commissioner will publish your GEAP on the Insights Portal

• Once the compliance review process is complete your GEAP will be published on the public data insights portal(opens in a new window).
• You will be notified before we publish your GEAP on the Insights Portal.

11.2 Notify your governing body, employees and employee representatives of the publication of your GEAP (required)

The Act requires you to notify your governing body, employees and employee representatives that you have published your GEAP.

This ensures transparency and accountability and will help you to continue to engage these important stakeholders in the success of your GEAP.

When people feel informed and involved, they are more likely to support changes.

Tips for communicating your GEAP

Your communication should aim to:

• educate – provide information so stakeholders understand and support the plan
• engage – inspire stakeholders to take part actively
• empower – encourage ownership and responsibility at all levels.

Consider the following when sharing your GEAP

• Choose the appropriate channels: Decide if you’ll use social media, internal networks, or other platforms.
• Set the tone: Choose a communication style that suits your audience – formal or conversational.
• Encourage dialogue: Foster 2-way communication. Consider creating groups or committees for employee involvement.
• Motivate participation: Think about incentives or recognition to encourage support for your gender equality initiatives.
• Prepare to respond to resistance and backlash: Visit VicHealth’s Encountering resistance: Strategies to respond to resistance to gender equality initiatives(opens in a new window) for guidance on how to manage this.

By sharing your GEAP, you can lay the groundwork for meaningful change. This will support successful implementation.

11.3 Ongoing engagement with your staff during GEAP implementation (recommended)

Regular engagement with your employees throughout GEAP implementation can keep them invested in achieving its vision.

It can also be used as an opportunity to gather and include real-time employee feedback on GEAP implementation.

Plan how to maintain this engagement in your GEAP, such as:

• maintain working groups. Use any groups formed during the GEAP’s development to help with implementation. These groups could be steering groups, employee networks or working groups. They can advise, engage employees and monitor progress. This helps to keep your organisation on track and accountable
• participate in networks. Continue to be involved in sector networks and communities of practice. Share ideas, resources and support
• ongoing employee consultation. Keep consulting with employees. Especially if strategies do not appear to be working. Employee feedback can help you adjust your strategies. Forming working groups for specific strategies can also support this process
• regular communication. Keep employees updated on GEAP progress (including celebrating successes) and how they can be involved. This could include making the GEAP implementation progress a standing agenda item in team meetings
• provide learning opportunities. Offer training and discussions on gender equality at work, the Gender Equality Act 2020 and the GEAP's role. This helps employees understand its importance and supports them in implementing it
• invite the Commissioner to visit your organisation and speak to your staff and board members (please contact enquiries@genderequalitycommission.vic.gov.au).

The Commissioner recommends you establish processes for monitoring your GEAP’s implementation.

12.1 Monitoring your GEAP implementation and outcomes (recommended)

Set up regular monitoring. This will help you report to your governing body (if you have one) about your progress under the Gender Equality Act 2020.

This will help ensure the governing body and executive team manage risks associated with non-compliance with the Act. In particular, there is an obligation to make reasonable and material progress on each of the 7 workplace gender equality indicators(opens in a new window) in every 2-year period).

Regular monitoring helps you find out which strategies are working, and which might need some adjustment.

It will also assist in documenting your progress. You will need to prepare progress reports around 2 years into the plan and at the end of the plan.

A well-structured monitoring system should:

• assign responsibility – outline who is responsible for what. This aids accountability and clarity
• document key decisions and reasons – keep clear records of decisions made during the planning process. This helps understand why you chose certain strategies, decisions or actions
• track milestones and outcomes – identify and track outcomes to measure the success of your GEAP’s strategies(opens in a new window)
• detect early warning signs – regular reviews can spot challenges or delays early. This allows for timely interventions to keep the plan on track
• inform continuous improvement – use feedback and data from monitoring to refine your strategies and measures(opens in a new window). This helps ensure the GEAP is adapted to changing circumstances
• inform stakeholder engagement – ongoing monitoring can also enable employees and stakeholders to be kept informed and engaged on progress. This promotes a sense of shared responsibility and ownership
• support evaluation and improvement – records help evaluate program success and find areas to improve. This is crucial for adjusting during the program or in future initiatives
• help ensure compliance – accurate monitoring helps inform appropriate governance of the obligations of the Gender Equality Act 2020 at the board and executive level.

Progress reports(opens in a new window) must include:

• the policies, programs and services that were subject to a gender impact assessment(opens in a new window)
• the actions taken due to each gender impact assessment
• your progress in relation to the workplace gender equality indicators(opens in a new window)
• your progress in relation to the strategies and measures set out in your gender equality action plan(opens in a new window)
• whether you met any relevant targets or quotas (note there are currently no targets and quotas regulated).

The Commissioner’s website has detailed information and guidance on what you need to do for each obligation.

Review guidance here:

• report on your progress(opens in a new window)
• undertake a workplace gender audit(opens in a new window)
• undertake gender impact assessments(opens in a new window) (GIAs) on every policy, program, or service (new or up-for-review) your organisation develops that has a direct and significant impact on the public.

Note that guidance on the website is subject to updates and amendments in each reporting period.

Maintaining privacy and confidentiality

You must maintain the privacy and confidentiality of your employees.

Do this by removing any personal details from your GEAP to protect your employees' anonymity.

When submitting your GEAP, inform the Commissioner if it contains any personal information. This is defined by the Privacy and Data Protection Act 2014.

You must remove any personal information before publishing the GEAP on your website.

For more details on privacy considerations, refer to How do I maintain my employees’ privacy?(opens in a new window)

Full list of how-to guides

Preparing your GEAP

• Creating a working group to help develop and implement your GEAP
• Using a range of data sources to inform your GEAP development
• Highlight where data gaps currently exist and your plan for building data collection
• Using intersectional analysis to understand data
• Outline any other information sources or data that were considered as part of your GEAP development
• Gaining leadership commitment

Planning and managing your consultation and engagement

• Define the purpose of your consultation
• Identify who you will consult
• Consult with union representatives
• Consult with your governing body
• Involve senior leaders
• Ensure effective consultation and engagement. This section includes:
  • Consultation methods
  • Budget and timeframe
  • Communication methods
  • Choosing who will lead the consultation
  • Supporting participants to feel safe
  • Consultation materials
  • Documenting and sharing consultation feedback
• Gather feedback and reflections

Developing a case for change

• Acknowledge existing efforts on gender equality
• Align with other equality commitments

Developing your strategies

• Use a comprehensive approach. This includes strategies on:
  • policies and processes
  • communication and engagement
  • education
  • data gaps and measuring change
  • pay equity principles
• Applying an intersectional lens
• Prioritising your strategies

Full list of further reading

Resources on gender equality and change

• Power to create inclusive gender equality in the workplace(opens in a new window) (Champions of Change coalition)
• Discussion guide on power to create inclusive gender equality in the workplace(opens in a new window) (Champions of Change coalition)
• Understanding and using your leadership influence(opens in a new window) (Champions of Change coalition)
• Encountering resistance: Strategies to respond to resistance to gender equality initiatives(opens in a new window) (VicHealth)

Resources to understand underlying causes of gender inequality

• Avoiding the merit trap(opens in a new window) (Champions of Change)
• Workplace equality and respect standards(opens in a new window) (Our Watch)
• Workplace equality and respect: how-to guide(opens in a new window) (Our Watch)
• Workplace positive duty standards(opens in a new window) (Our Watch)
• Inclusive workplace toolkit: understanding different kinds of discrimination(opens in a new window) (Hue Colour the Conversation)
• Gender identity(opens in a new window) (Victorian Equal Opportunity and Human Rights Commission)
• The Man Box: the attitudes and behaviours of Australian manhood(opens in a new window) (Jesuit Social Services)
• Unpacking intersectional approaches to data(opens in a new window) (Global Partnership for Sustainable Development Data)
• The ‘but why?’ technique(opens in a new window) to understanding underlying causes of gender inequality (Community Toolbox)

Resources on developing a case for change

• WGEA’s workplace gender equality: the business case(opens in a new window) (WGEA)
• A guide for inclusive gender equality by design(opens in a new window) (Champions of Change coalition)
• Inclusive workplace toolkit – understanding different kinds of discrimination(opens in a new window) (Hue Colour the Conversation)
• Change the story: a shared framework for the primary prevention of violence against women(opens in a new window) (Our Watch)

Resources on setting targets for gender equality

• Guide to setting gender targets(opens in a new window) (Workplace Gender Equality Agency)
• Target setting for gender equality: a review of the literature(opens in a new window) (Workplace Gender Equality Agency)
• What works, what’s fair(opens in a new window) (promoting workplace gender equality), the University of Melbourne, Australian National University and Swinburne University of Technology (Commission for Gender Equality)
• Employer of Choice for Gender Equality: leading practices in strategy, policy and implementation(opens in a new window) (Workplace Gender Equality Agency)
• Accelerating workplace gender equality toolkit(opens in a new window) (Gender Works)