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particularly important to demonstrate that the system is leading to changes in the way in which policy and practices are developed where necessary.  Publishing this information, for example in reporting on the gender duty in the public authority's main annual report, will build the confidence of stakeholders in the robustness of the authority's approach to gender equality.

Implementing the scheme


Listed public authorities are expected, within the three year period, to implement:

their actions for gathering and using information

the objectives in their scheme.


If a public authority does not comply with any specific duty imposed by the Order, including implementing the elements indicated above, the EOC or CEHR may issue a compliance notice (see Chapter 4 for further information about enforcement).  


The public authority will not be under an obligation to implement their actions for gathering or using information or to implement the scheme objectives if, in all the circumstances of the case, it would be unreasonable or impracticable for it to do so.   The words 'unreasonable' and 'impracticable' are intended to relate to particular and unforeseen circumstances.  For example:

where there are particular difficulties with implementing objectives in the scheme but these difficulties could not have been foreseen, then it is likely to be unreasonable to have to implement them

where costs associated with an action unexpectedly escalate so as to be out of proportion to the duty, then it is unlikely to be practicable to implement the duty.


It is important, however, that public authorities consider other solutions where it is not reasonable or practicable for them to carry out a particular part of the scheme.  Once barriers to equality have been identified, an authority will need to address them, considering alternative methods of overcoming them if those proposed originally are not practicable or reasonable.    

Annual reports


Listed public authorities must take such steps as are reasonably practicable to publish annually a report, summarising the actions they have taken to implement their scheme objectives.  This report can be published as a separate document or within another published document, for example, the public authority’s main annual report.   

Reviewing and revising the scheme


Listed public authorities have an obligation to review and revise the scheme every three years.  It is recommended that this should involve a review of progress to date and of the appropriateness of the previous scheme objectives, with a view to continuous improvement in the implementation of the duty.  Evidence for this process would include the information gathered to date, the results of impact assessments, and any feedback from stakeholders on the effectiveness of the preceding scheme.  

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