Review of 2025-26 obligation processes

Evaluating the 2025-26 obligation cycle

The Commission has undertaken an evaluation of the 2025-26 obligation cycle. It covered preparation and submission of 2025 audits, 2026 progress reports and 2026 gender equality action plans (GEAPs). The review aimed to identify positive outcomes as well as opportunities for improvement.

The review considered the Commission’s supports and processes, as well as feedback from duty holders about their experiences. Duty holders provided feedback via online surveys – which attracted more than 230 responses – and through submissions from communities of practice.

Findings from the review will shape the Commission’s approach to the next obligation cycle in 2027-28.

This review did not include compliance feedback and enforcement action. This activity will be evaluated when compliance activity is complete.

What worked well

Feedback from duty holders identified a number of areas that worked well.

Guidance and supports were widely used

To help duty holders prepare and submit their obligations, the Commission delivered a range of resources and supports. This included:

• an induction webinar for new duty holders that attracted more than 380 registrations
• step-by-step instructional videos to help duty holders use obligation templates and the reporting platform, which attracted more than 1,300 views across 7 videos
• 30 online drop-in sessions focusing on reporting obligations, giving duty holders access to subject matter experts from across the Commission
• newly developed performance measures to support organisations to analyse their data effectively and efficiently
• a new guidance note for using the performance measures, Analysing your audit results, which attracted more than 1,700 webpage views
• a new Performance Report on the Commission’s Reporting Platform to generate performance measures and help duty holders analyse their audit data and use it for GEAP and progress reporting, used by almost 90% of duty holders
• compliance rubrics for GEAPs and progress reports, which attracted more than 260 webpage views.

Resources and supports were helpful

Feedback from duty holders showed that the resources and support we provided were helpful. More than 90% of survey respondents found our audit guidance helpful, 86% found our GEAP guidance helpful, and 83% found our progress report guidance helpful.

In 2025-26, Commission staff managed more than 2,600 enquiries, an increase of more than 50% compared to the previous year. We maintained an average first response time of 2 days and an average satisfaction score of 4.6 out of 5.

What could be improved

Feedback from duty holders identified a number of areas that could be improved.

Reporting requirements can be complex and time-consuming

A common theme in duty holder feedback was the scope and complexity of the obligations. Some duty holders said that reporting was too time-consuming. Some smaller organisations said they felt under-resourced to meet their regulatory requirements.

Templates and guidance can be difficult to use

While many duty holders found the templates for progress reports and GEAPs helpful, some duty holders found them challenging. Suggestions for improvement included simplifying templates, reducing duplication, and improving flexibility within the template.

For audits, duty holders most commonly needed help to understand data definitions or requirements. Many also needed help to understand results provided in Reporting Platform reports.Some duty holders said guidance was too long or difficult to navigate. Others asked for more guidance such as worked examples.

Access to drop-in sessions can be limited

While hundreds of duty holder representatives attended one or more online drop-in sessions, not everyone was able to access them. The Commission delivered 30 drop-in sessions, with attendance capped to ensure participants had time to ask questions. Feedback suggests that uncapped sessions may be preferred, to allow higher attendance numbers. Some duty holders asked for a record of questions and answers from each drop-in session to be published.

Actions for the Commission

Based on the review, the Commission will take action to improve processes and supports for future obligation cycles. We will:

• adjust the design of online drop-in sessions to improve access and information-sharing
• update the GEAP and progress report templates to simplify and improve usability where possible, while minimising changes that impact duty holders’ internal processes
• update guidance documents to simplify, improve plain language, and improve navigation where possible
• explore changes to website architecture to improve access to guidance materials
• update the Commission’s Reporting Platform to improve utility and usability of data reports.

What happens next

We know that reporting to us every 2 years takes a lot of time. In the longer term, we will continue to explore how our regulatory approach can most effectively address the greatest harms. This will include delivering on the government’s response to the four-year review of the Gender Equality Act, which supports a proportionate approach to assessing progress.