GEAP 2026: Understanding compliance feedback

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Overview

Who is this page for?

This page is for organisations with 2026 gender equality action plans (GEAP) that have areas marked as "did not demonstrate compliance”. It will help you understand what is required to demonstrate compliance in future cycles.

What does this page contain?

This page lists the criteria that we used to assess your GEAP. We explain why your GEAP may not have demonstrated compliance, with reference to the Act and Regulations. You should use this page when making changes to your GEAP before resubmitting. We ask you to make changes and resubmit where you were assessed as not demonstrating compliance against one or more of the 11 criteria listed below.

To find which criteria the Commission marked as “compliance not demonstrated” for your organisation, check your GEAP outcome report on the Reporting platform.

To learn more about how to resubmit your GEAP, see How to resubmit your gender equality action plan on our website.

Criterion 1: Attestation

The head of organisation attests the GEAP and its resourcing.

Common issues

  • One or more attestation boxes were not marked.
  • The attestation was completed by someone other than the head of organisation.
  • The head of organisation did not include their signature and date.
  • A foreword from the head of organisation was included, but the required attestation wording was missing.

How to demonstrate compliance

  • Mark all required attestation boxes.
  • Ensure the head of organisation completes the attestation. This cannot be delegated.
  • Ensure the head of organisation provides their name, title, signature and date.

Criterion 2: Board consulted

The duty holder consulted with the governing body.

Common issues

  • There was no evidence that the governing body was consulted, or consultation was planned for after the GEAP was submitted.
  • Your GEAP said the governing body had been consulted, but other information in the GEAP indicated this had not yet happened.
  • There was no confirmation or evidence that the governing body was consulted.

How to demonstrate compliance

  • If your organisation does not have a board or governing body, this criterion does not apply.
  • Confirm, or provide evidence, that the governing body was consulted during the development of the GEAP.
  • Undertake at least one round of consultation with your governing body.
    • If you conducted appropriate consultation, but did not report on it clearly, update your GEAP to include this information.
    • If you did not conduct appropriate consultation, you will need to do this before resubmitting your GEAP. This may require broader changes to your GEAP based on the consultation outcomes as a result.
  • For future GEAPs, be aware that:
    • Consultation must happen during the development phase, before the GEAP is submitted.
    • If you are in local government, councillors must still be consulted.
    • If your board is appointed by a minister, they must still be consulted.
  • To review the relevant section of the guidance, see Step 3: Consult on your audit results, and Step 7: Consult on your strategies.
  • You can find further advice in the How-to guide: Consulting with your governing body.

Criterion 3: Employees consulted

The duty holder consulted with their employees.

Common issues

  • There was no evidence that employees were consulted, or consultation was planned for after the GEAP was submitted.
  • Your GEAP said that employees had been consulted, but other information in the GEAP indicated this had not yet happened.
  • The evidence suggested that only a small group of employees were given the opportunity to be consulted.
  • Enterprise bargaining processes, running a broader employee experience survey that is not focussed on the GEAP (such as the People matter survey), and the use of previous feedback are not considered as employee consultation for GEAP development.

How to demonstrate compliance

  • Confirm, and provide evidence, that a broad cross section of your employees was consulted during the development of the GEAP.
  • Undertake at least one round of consultation with your employees.
    • If you conducted appropriate consultation, but did not report on it clearly, update your GEAP to include this information.
    • If you did not conduct appropriate consultation, you will need to consult before resubmitting your GEAP. This may require broader changes to your GEAP as a result of the outcomes of the consultation.
  • For future GEAPs, be aware that:
    • Consultation must happen during the development phase, before the GEAP is submitted.
    • Consultation of employees must be broad and inclusive. Ideally all employees should be given the opportunity to have a say in the development of the GEAP. Consulting only a small group of staff, such as a committee or working group, is not enough.
  • To review the relevant section of the guidance, see Step 3: Consult on your audit results, and Step 7: Consult on your strategies.
  • You can find further advice in the How-to guide: Consultation and engagement.

Criterion 4: Union consulted

The duty holder consulted with their employee representatives, including relevant trade unions.

Common issues

  • There was no evidence that employee representatives were consulted, or consultation was planned for after the GEAP was submitted.
  • Your GEAP said that employee representatives were consulted, but other information indicated this had not yet happened.
  • Your GEAP said that employee representatives were not consulted but did not provide enough information to explain why.
  • Your GEAP said that your organisation did not have employee representatives, including representatives of relevant trade unions, within its organisation. In this case, you must reach out to the relevant union(s) and provide the opportunity for them have input into the GEAP.

How to demonstrate compliance

  • Confirm, and provide evidence, that employee representatives, including relevant trade unions, were consulted during the development of the GEAP.
  • Undertake at least one round of consultation with your employee representatives, including relevant trade unions.
    • If you conducted appropriate consultation, but did not report on it clearly, update your GEAP to include this information.
    • If you did not conduct appropriate consultation, you will need to consult before resubmitting your GEAP. This may require broader changes to your GEAP as a result of the outcomes of consultation.
  • For future GEAPs, be aware that:
    • Consultation must happen during the development phase, before the GEAP is submitted.
    • Take all reasonable steps to contact employee representatives, including relevant trade unions. If there is no engagement from the union(s), explain this clearly and describe the steps taken to seek their input.
  • To review the relevant section of the guidance, see Step 3: Consult on your audit results, and Step 7: Consult on your strategies.
  • You can find further advice in the How-to guide: Consult with union representatives.

Criterion 5: Consultation process

The duty holder describes the consultation process.

NOTE: If criteria 2, 3 or 4 were assessed as non-compliant, this criterion was automatically marked as non-compliant.

Common issues

  • Insufficient information was provided to understand the consultation process.

How to demonstrate compliance

  • Show that you consulted your board or governing body, employees, and employee representatives, including relevant trade unions, during the development of your GEAP.
  • Include enough information to explain how consultation was carried out. For example, describe:
    • the number and format of consultation sessions
    • the purpose of each session
    • the communication methods used
    • who led the consultation
    • how participants were supported to feel safe taking part
    • reflections on the consultation process.
  • To review the relevant section of the guidance, see Step 3: Consult on your audit results, and Step 7: Consult on your strategies.
  • You can find further advice in the How-to guide: Consultation and engagement.

Criterion 6: Gender equality principles

The duty holder considered the gender equality principles in developing their GEAP.

Common issues

  • There was no evidence that the gender equality principles were considered during the development of the GEAP.
  • Simply listing the gender equality principles, without explaining how they were considered, is not enough.

How to demonstrate compliance

  • Describe how the gender equality principles were considered during the development of the GEAP.
  • Demonstrate you have considered the principles in relation to:
    • building the case for change and/or vision
    • guiding consultation discussions
    • informing decision-making during strategy development
    • engaging the leadership team, and/or
    • any other aspect.
  • To review the relevant section of the guidance, see Step 4: Consider the gender equality and gender pay equity principles, and intersectionality.

Criterion 7: Gender pay equity principles

The duty holder considered the gender pay equity principles in developing their GEAP.

Common issues

  • There was no evidence that the gender pay equity principles were considered during the development of the GEAP.
  • Simply listing the gender pay equity principles, without explaining how they were considered, is not enough.

How to demonstrate compliance

  • Describe how the gender pay equity principles were considered during the development of the GEAP.
  • Demonstrate you have considered the principles in relation to:
    • guiding policy making/changes related to gender pay equity
    • analysing your audit data
    • informing your consultation process
    • your organisational values, and/or
    • developing strategies.
  • To review the relevant section of the guidance, see Step 4: Consider the gender equality and gender pay equity principles, and intersectionality.

Criterion 8: Audit data

The duty holder describes the results of the workplace gender audit against each indicator. This must include audit data from 2025, ideally using the performance measures as a minimum.

NOTE: You are required to include workplace gender audit data for each indicator in your GEAP. The performance measures are the Commissioner's recommended way to provide your data.

Common issues

  • Numerical data was missing, incorrect, or interpreted incorrectly. For example:
    • Indicator 7 – gendered segregation within the workplace: overall workforce composition was provided instead of data for each occupational group.
  • The gender inequality issues shown by the data were not explained.
  • There was not enough relevant data for each indicator, making it difficult to understand the issues.
  • Some of the data provided was not relevant to the indicator.
  • The data was not disaggregated by gender.
  • Data was stated to be unavailable, but this was not adequately explained or did not align with 2025 workplace gender audit data submitted by the organisation to the Commissioner.

How to demonstrate compliance

  • Include enough relevant data for each workplace gender equality indicator. Ideally, use the performance measures already in the template where available. Data gaps were most common for indicators 4 – sexual harassment, and 7 – gendered segregation. To demonstrate compliance on these indicators:
    • For Indicator 4 – sexual harassment, include at a minimum the anonymous survey rate of sexual harassment experience (disaggregated by gender) and the number of formal reports (workforce data). If your gender-disaggregated survey data is suppressed due to privacy thresholds, please provide the whole-of-organisation rate (i.e. not gender-disaggregated).
    • For Indicator 7 – gendered segregation within the workplace, provide data for each occupational group represented in your organisation. If the ANZSCO codes are not useful groupings for your organisation, consider analysing groups that are more meaningful for you. This may include, for example, ‘customer-facing roles’, ‘outdoor maintenance team’ or ‘systems and IT’.
  • Describe the gender inequality issues shown by the data.
  • Use data from your workplace gender audit for the relevant reporting period.
  • Include sufficient data for each indicator. Using more than one data point can improve accuracy and confidence in the issues identified. This ensures your strategies are sufficiently targeted. Using multiple data point is particularly important for sexual harassment. To understand, prevent and address sexual harassment in your organisation, you must consider your anonymous survey data and your formal reporting data together.
  • For future GEAPs, be aware that:
    • Robust data collection will be expected for the next GEAP. If your survey data is suppressed in future reporting rounds, consider alternative forms of data collection. This could include consulting on this issue with your workforce to estimate what might be happening in your organisation. Sexual harassment is a serious work health and safety issue, and duty holders are legally required to take proactive steps to prevent and eliminate sexual harassment under a range of legislation.
  • The Commissioner has published her expectations for making progress on each of the indicators. For future GEAPs, these can help you consider what data to analyse in order to develop appropriate strategies. To read the Commissioner’s expectations for each indicator, see:
  • To review the relevant section of the guidance, see Step 2: Analyse your audit data to identify forms of gender inequality.
  • You can find further advice on how to analyse your data in the Analysing your audit results guidance note.

Criterion 9: Strategies

The duty holder includes strategies based on the audit, which promote gender equality in the workplace, against each indicator.

Common issues

  • Some strategies were not relevant to the indicator. For example:
    • Indicator 2 – gender composition of governing bodies relates to the gender composition of the governing body, not the composition of the senior leadership team or other committees.
    • Indicator 7 – gendered segregation within the workplace relates to occupational gender segregation. It is distinct from Indicator 1, which considers the gender composition of the organisation, including the gender composition at different levels of seniority.
  • Some strategies were framed as goals or aspirations rather than clear actions to address gender inequality.
  • Some strategies were not related to gender equality.
  • Some strategies appeared to be business-as-usual activities rather than targeted actions to address gender inequality.
  • Some strategies were actions required under the Gender Equality Act 2020, rather than strategies in their own right. Required actions on their own are not enough. Examples include:
    • undertaking a workplace gender audit
    • mapping occupations to ANZSCO codes
    • reviewing employee experience data
    • communicating the GEAP to employees.

How to demonstrate compliance

Criterion 10: Measures

The duty holder includes measures to assess progress towards the promotion of gender equality in the workplace against each indicator.

Common issues

  • There were no suitable measures to track success.
  • Where the performance measures already listed in the template were not used, the alternative measures:
    • were process measures that did not adequately track success against the indicators. For example, measuring how many training sessions were delivered will not show whether outcomes improve
    • were not clearly related to the indicator
    • were too vague to be useful measures, for example including “average gender pay gap,” which is not specific enough. Use something more targeted, such as “mean total remuneration pay gap” or “median base salary pay gap”.

How to demonstrate compliance

  • Use the performance measures already listed in the template where possible. If you do not use the performance measures, then your alternative measures must:
    • relate directly to the relevant gender equality indicator
    • be grounded in your workplace gender audit data and
    • enable you to assess progress towards workplace gender equality against that indicator.
  • To review the relevant section of the guidance, see Step 6: Develop strategies and measures.

Criterion 11: Resourcing

The duty holder includes a resourcing plan to implement their GEAP.

Common issues

  • There was no evidence of staff, budget, capability, or other support to deliver the GEAP.
  • Your GEAP relied on a possible merger or future organisational changes as part of the approach to implementation.
  • The information provided was too brief to show that the organisation was ready to implement the actions.
  • Future plans or a commitment to consider resourcing for GEAP implementation are not adequate.

How to demonstrate compliance

  • Make sure the GEAP has appropriate staff, budget, capability, and other support for implementation. Adequately resourcing your obligations under the Act is a requirement and is the responsibility of the Head of Organisation.
  • Clearly state this resourcing in your GEAP.
  • To review the relevant section of the guidance, see Step 8: Resource your GEAP.

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