With just a few months to go until new gender equality target-setting requirements come into effect, WGEA’s Executive Manager of Insights and Capability answers five common questions about the new requirements.

From April this year, Australian employers with 500 or more employees will need to move beyond measuring gender equality outcomes to formally setting targets to improve them.

The new requirements form part of WGEA’s broader strategy to address gender inequity, building on the compulsory publication of gender pay gaps, which commenced for most employers in 2024.

“The target-setting is about locking in accountability for doing something about [gender equality],” says Dr Samone McCurdy, Executive Manager, Insights and Capability at the Workplace Gender Equality Agency (WGEA). 

“We’re tracking and measuring progress at a national level, but also empowering organisations to track it at an individual or workplace level. It’s those two things working in unison that will create momentum.”

Employers covered by the legislation will need to select their targets during the WGEA reporting period, from 1 April to 31 May 2026. They can choose from a list of 19 gender equality targets laid out in WGEA’s Targets Menu.  

The list includes both action-based and numeric targets, such as: 

• Gender composition of the workforce (numeric). Example: Increase representation of women among senior managers by X per cent.
  
• Reducing the gender pay gap (numeric). Example: Close average base salary gender pay gap by X per cent. 
• Improve facilities or support for employees with caring responsibilities (action). Example: Provide breastfeeding facilities and employer-subsidised childcare for carers.
• Employee consultation on gender equality issues (action). Example: Consult annually with an employee diversity committee or equivalent and consult on gender equality during experience surveys and exit interviews.

At least one of the three targets selected must be numerical. Employers will not be allowed to change or abandon targets once they have been set.

“The legislation is asking organisations, particularly boards and C-suites, to meaningfully and purposefully intervene in creating gender-equal experiences,” says McCurdy. 

“In order to [achieve that], leaders need [at least] a bit of gender literacy – it’s not something they can just shoot off to the remuneration committee.”

Below, McCurdy clears up common areas of confusion around the new requirements, including choosing the right targets for your business and HR’s role in supporting businesses to meet the requirements.

Watch AHRI’s on-demand webinar to hear more from McCurdy and other experts on what the WGEA reporting changes mean for you, and how to confidently meet the new requirements. Not an AHRI member? Sign up now.

1. How can employers decide which targets are best suited for them?

When selecting their targets, McCurdy stresses that employers need to strike the right balance between ambition and realism.

“[For example], if an organisation is wanting to work on their gender composition, and they have three per cent women in their organisation, I would never recommend going for a 50/50 split, because that becomes less tangible,” she says.

She recommends starting with a thorough diagnostic across the organisation – looking at areas such as workforce composition, pay equity, recruitment, promotion rates and retention data – to identify where intervention will have the greatest impact.

“A comprehensive analysis is one that looks at not just your like-for-like pay gaps, but also where gender is showing up in the experience of your employees,” she says. 

“It might be in [certain] candidate pools or particular jobs. It might be around returning to work from parental leave.”

She also recommends looking at past trends in your organisation in the gender equality space and tracking how quickly progress was made. 

For example, if your organisation’s gender pay gap has improved or worsened by a few percentage points over the past five years, an increase of that same percentage or slightly more might be an appropriate numerical target. 

“That’s a really good way to approach it, because it gives you a stretch, but it’s not so easy that it becomes meaningless.”

Key resources: 

• WGEA: Gender Pay Gap Analysis Masterclass (free).
• AHRI infographic: How to set gender equality targets in line with new WGEA requirements
• AHRI article: New reporting tool offers insights into systemic drivers of gender pay inequity.

2. How flexible are the targets once they’ve been set?

The legislation states that employers must either meet or make ‘meaningful progress’ on their targets within the three-year reporting period.

This means employers will not automatically be non-compliant if they don’t achieve the exact numeric target they were aiming for.

“If something has shifted in your chosen metric by one per cent, that’s progress. If you said 10 per cent [initially], but a few things have happened and you’ve ended up with two per cent, you are still compliant, because you’ve made an improvement,” says McCurdy.

Action-based targets are less flexible, since a committed initiative – such as better carer facilities – will either have been implemented or not after the three-year reporting cycle. 

There may be extenuating circumstances where employers can provide a reasonable excuse for missing targets – for example, a merger or acquisition that disrupted operations. 

However, if employers don’t meet their targets and cannot provide a reasonable excuse, they risk being publicly named by WGEA.

“[They may also] not be able to continue in their procurement for government contracts and services,” says McCurdy.

Key resource: WGEA: Consequences of non-compliance.

“A comprehensive analysis is one that looks at not just your like-for-like pay gaps, but also where gender is showing up in the experience of our employees.” – Dr Samone McCurdy, Executive Manager, Insights and Capability, WGEA.

3. How can employers align existing gender equality strategies with the new framework?

For many businesses, the new requirements will simply formalise work that’s already underway. 

“Most Australian organisations are really engaged in this work, and they want to do well,” says McCurdy. “In the whole time I’ve been working in gender equality, I haven’t [seen] employers sit back and say, ‘We don’t really care about this.’”

In businesses with gender equality initiatives already in place, employers will simply need to align the work they are already doing with three of the targets on WGEA’s list. 

Rather than creating more work, setting the targets formally will allow them to protect the momentum of their existing strategy and put accountability frameworks in place to ensure follow-through.

“The trick is to find out what kind of uplift [a strategy] is going to create, and then select targets accordingly,” she says.

Key resource: WGEA: Gender equality policy and strategy guide.

4. How much of the data will be publicly available?

The targets employers set will be visible via WGEA’s Data Explorer, alongside their gender pay gap.

“At the end of that three-year period, it will be updated to show the progress that is being made,” says McCurdy. 

With the right approach, she says, employers can turn this transparency into an asset rather than a vulnerability. 

Target reporting provides a more contextualised picture of where an organisation is heading than a single pay gap figure alone. While a pay gap snapshot might create more questions than answers, published targets and progress updates show the strategy and intent behind the numbers – and whether the organisation is taking credible steps to improve.

What’s more, the Data Explorer allows employers to explore strategies from other organisations and learn from them.

However, the high level of visibility over the targets means employers should also be preparing managers for inevitable questions from employees and candidates, says McCurdy.

“This is part of what we’re calling ‘gender-attuned leadership capability’, where they’re able to lean into [those conversations] and say, ‘This is the state of play at the moment, and this what we’ve got in place [to address it]… and we are welcoming candidates who want to come and be part of that.’”

Key resources to help you: WGEA Data Explorer.

5. How can HR ensure accountability and follow-through?

McCurdy, who has an HR background, says the new requirements present exciting opportunities for HR to further build their influence and credibility. 

“We’ve always been capable of knowing how people and culture can come together to uplift business… But we haven’t always had the mandate to bring that knowledge to the table,” she says.

“What this legislation does so beautifully is create true collaboration and cooperation across that coalition of influence – boards, C-suites, HR, diversity practitioners, and down to line managers, who we all know create the employee experience every day.”

She encourages HR to position gender equality targets as an enterprise governance issue, not a compliance task. That means bringing the board and executives into a “contest of ideas” early: what outcomes matter most, what trade-offs the organisation is prepared to make and what meaningful progress would look like over three years.

From there, HR’s influence lies in creating the conditions for follow-through. An important piece in this puzzle is equipping line managers with the practical tools and gender literacy to translate goals into everyday decisions, and ensuring they are not intimidated by the prospect of formal targets.

“It’s not a destination. It is an enabling framework that impacts day-to-day experiences, so we’re not [hearing things like], ‘That’s a job for blokes,’ or ‘I’ll never get that role because I can’t do it part time,’” says McCurdy.

“It’s about bringing those [issues] to the fore and building the capability, particularly among line managers, to be able to [address] them.”

All information, content and materials available on this site are for general informational purposes only. The contents of this article do not constitute legal advice and should not be relied upon as such.

AHRI members can hear from McCurdy and other experts in this on-demand webinar on what the WGEA reporting changes mean for you, and how to confidently meet the new requirements. Not an AHRI member? Sign up today.