Gender impact assessments: do the thinking, not the form

Five years in, most organisations are still finding this hard

Since the Gender Equality Act 2020 began, defined entities have had to complete a gender impact assessment (GIA) whenever they develop or review a policy, program or service with a direct and significant impact on the public. On paper, the duty is being met. In practice, the tool is not doing much work.

The statutory review of the Act, conducted by Cube Group for the Office for Women and tabled in Parliament in August 2026, found that GIAs and the intersectionality requirements have faced the most barriers of anything in the Act. Duty holders called the template 'very academic, lengthy and full of jargon', and many staff said they lacked the skills to do one. That matches what I see.

It does not need to be this way. This is a design problem, not a people problem, and design problems can be fixed.

Why it matters

Public institutions should serve the public, all of it. Councils, hospitals, universities and government departments decide every day who can use a service, and when, where and how. Those decisions are never neutral. When a service is designed around one kind of user, everyone else has to work around it, and the cost tends to fall on the same people: women, carers, and people who are already experiencing marginalisation.

The Act deals with both sides of this. A gender equality action plan (GEAP) looks inward, at the workforce: who is hired, paid, promoted and kept safe. A GIA looks outward, at the policies, programs and services the community relies on. The two belong together. An action plan changes how an organisation treats its own people. A GIA changes what it delivers to everyone else. And the two are linked. Services are designed by staff, so an organisation that is unequal on the inside usually ends up delivering unequal services on the outside. That is the point of a GIA: not to complete a form, but to make public services work better for people of all genders.

From 'did you do one?' to 'did it change anything?'

Until now, progress reports asked duty holders to summarise each assessment in a table: what it was, its status and the actions taken. The Commissioner saw only that summary, not the assessment itself, and she found that many duty holders gave 'brief, inadequate responses offering little insight as to whether GIAs are being undertaken effectively'.

The 2026 round was different. The Commissioner named GIAs as one of her three compliance priorities, alongside sexual harassment and the gender pay gap, and asked organisations to report only on assessments where it was clear what changed, or that nothing would. Feedback on those reports has now landed, and for many organisations, GIAs were where they fell short of compliance. A common gap was that assessments did not say how the change would improve gender equality.

The next round is likely to look closer still. The statutory review recommends that duty holders hand over actual assessments, or a sample, so the Commissioner can judge their quality, which is what she asked for in her own submission to the review.

The question is no longer whether you did one. It is whether it changed anything.

What gets in the way

The Commission's guidance is thorough, and most in-house templates inherit its structure: four steps, from defining the issues and challenging assumptions, through the policy context and an options analysis, to a recommendation. The Commission has been improving its resources, and the statutory review recommends simplifying them further. But in practice, especially in local templates, seven things make it hard to use well.

• Too long. Dozens of pages to read before you can begin, which is a lot to ask of a busy program manager.
• Too much jargon. Terms like 'gender-transformative' are correct but land as loaded words for anyone without gender studies training.
• One size for everything. A footpath renewal and a ten-year strategy use the same template, so neither gets the right tool.
• Not seen as core business. Completing the template becomes the goal, rather than improving the policy, program or service.
• The loop stays open. Nobody tracks whether assessments changed anything, which confirms the sense that they are paperwork.
• Authority is assumed. The template assumes the person completing it can change the policy, program or service. Often they cannot, and nobody has asked who can.
• Nobody owns it. GEAPs usually sit with people and culture and are properly governed. GIAs often have no clear owner, and the training goes to people and culture staff rather than the planners, program managers and service designers doing the work, many of whom do not know the duty applies to them. The duty is formally on the books and practically orphaned.

Do the thinking, not the form

Underneath all seven is a bigger problem. A GIA has three parts: doing, recording and reporting. Most of the effort goes into the last two.

• Doing is the real thinking. Who is it built for, who is not using it, and what will we change? The Act does not prescribe how.
• Recording is your local template or app. Keep it proportionate to the decision.
• Reporting is a few narrow questions in your progress report: what the assessment was, its status, the actions taken (or why none were), and how intersectionality was considered.

The tools were built to capture information, when the real job is to provoke thinking. So people fill in the form after the decision has been made, and few assessments change anything. It needs to work the other way around: an honest conversation with the person doing the work first, then a record of what was decided. Start with what can actually change. Who needs to approve it? Is there budget? Often there is not, because budgets are set long before the work begins. If a change cannot happen now, say so, and note what would need to happen for it to happen later.

The record still matters, because it shows what changed. But the progress report shows that something happened, not whether anything improved. Do this work to make real improvements to gender equality, not just to complete a form.

You do not have to be an expert

This is where many people get stuck. They assume a GIA needs a gender specialist, so they wait for one or hand it to the gender equality lead or human resources. It needs neither. The statutory review found that assessments need to be done by someone with a deep understanding of the policy, program or service itself. That is the planner, the program manager or the service designer.

What they need is not a qualification. It is targeted questions, permission to ask them, and someone to talk it through with when the answers are not obvious. They also need the authority to make the change, or a commitment from someone who has it.

GIAs made simple

Strip it back and a GIA is one question, asked early and answered honestly: who was this built for, and who has to work around it? Four steps, and the questions to ask at each, help you answer it.

1. Name who it is built for, and who has to work around it. Who is the default user? Who will find this easy, and who might find it difficult?
2. Look honestly at who is served, and who is not. Do we know who is using this service, and why? What does the evidence tell us about who is not using it? Break it down by gender wherever you can. Missing data is a finding, not a reason to skip the analysis: say so, and make better data collection one of the actions.
3. Change the design to remove the barriers. Does a barrier sit in something simple: hours, waiting times, the channel or a form? Who owns this decision, and can we actually change it? The change can be small.
4. Record what you decided, and why. If nothing changed, record why not, for example because the decision is outside the organisation's control.

When you consult, recognise people's time properly. The people a system disadvantages should not be the ones doing the work of fixing it.

Name the default user

Most guidance asks you to list the groups affected. That treats intersectionality as a list of overlapping identities, which is only part of what it means. It is also a way of seeing how systems and structures create inequality: who something was designed to serve, and how power works inside it. Most institutions were built around an assumed user who is male, able-bodied, cisgender, heterosexual, English-speaking and white. Naming that user points at the design rather than the people, and design is something you can change.

Keep gender at the centre

A question as broad as 'who was this built for?' can drift into a general accessibility review. Every assessment still needs to say plainly how the policy, program or service affects people of different genders, what you will change, and how that change addresses gender inequality and promotes gender equality. That is what the Act asks for, and it is often the part that goes missing. Intersectionality deepens the gender analysis. It does not replace it.

Three sizes, not one template

Keep the recording proportionate to the decision.

What a change can look like

The changes do not have to be big, and they are rarely a physical fix like a ramp. Most barriers sit in a policy or service. A few illustrations of what an honest assessment can surface:

• A council's community grants round. The round closes in the middle of the school holidays. It is built for applicants without caring responsibilities, who can prioritise this work. It misses parents and primary carers, who are more likely to be women and often take leave over the school holidays. The change: move the closing date out of the school holidays. This thinking also prompted a check for other dates that might stop people applying, such as days of cultural or religious significance. When Horsham Rural City Council assessed its community grants program, it found that applications written by men asked for more funding on average.
• A council's kindergarten enrolment line. Most callers are mothers and other primary carers, many of them also working, but the line is only open from 9 am to 5 pm on weekdays and calls peak around school drop-off and pick-up. Opening in the early evening, offering a call-back and letting people enrol online means parents are not stuck on hold at pick-up time or taking time off work to make a phone call.
• A kerbside bin service. In one of the Commission's worked examples, drawn from real cases, a council found that the people managing household waste, nappies and incontinence products were mostly women, and that some households produce far more landfill than others. It offered those households a larger bin and aimed its recycling campaigns at men.
• An online form. First ask whether you need gender data at all. If you do, ask which you actually need: gender, or sex recorded at birth. Usually it is gender. Then collect it the way the Commission does: woman, man, a free-text option to self-describe, and prefer not to say. Asking for a chosen name rather than a 'preferred' name costs nothing, and it stops the form excluding people at the first screen.

Each one started with the same question: who was this built for, and who has to work around it? The Commission's own case studies show the same pattern in services as varied as animal management, public toilets, place names, infringements and evacuation centres.

Where to start

• Give assessments a clear owner, and put the training in the hands of the people who design public-facing work.
• Build the questions into decisions you already make, such as budget bids, project initiation and policy review, rather than adding another form at the end.
• Write any template for busy people: plain language, a finished example next to the blank questions, and 'you do not have to be an expert' said out loud.
• Close the loop. Tell people what recent assessments actually changed. A short, regular update does more for take-up than any amount of guidance, and it is exactly the evidence the Commissioner will be looking for.