What countries does this apply to?
- England England
- Scotland Scotland
- Wales Wales
Introduction
Our 2025 to 2026 business plan is the first year of delivery against our new strategic plan.
It is a period of change for the Equality and Human Rights Commission (EHRC) as we move from delivering our work in a programmatic way to a more agile way of working, which prioritises our ability to respond to emerging and immediate issues, alongside our core responsibilities.
We will still work to achieve impact through longer term system and behavioural changes, but this will be through a smaller number of very targeted programmes of activity.
This shift will allow us more opportunity to challenge the issues that face society now and in a timelier way, ensuring that everyone’s rights are upheld and delivering our ambition to influence and achieve longer term change for society.
Our planned activity is organised under our three pillars of work, as set out in our strategic plan.
Pillar One: Regulating equality and human rights
We will deliver a core programme of regulation to support compliance with equality and human rights law. Our work under this pillar in 2025 to 2026 will focus on our statutory and core remit.
We will maintain and promote an authoritative and comprehensive evidence base through our Equality and Human Rights Monitor, which we will regularly update. We will continue to evolve our approach to data analysis and how we share and use this information to prioritise and conduct our work.
We will continue work to ensure that our core guidance and codes of practice are clear, comprehensive and up to date so that duty bearers have the information to help them understand their specific obligations.
We will continue to seek compliance by duty bearers with their statutory responsibilities and take action where we find that there are breaches of the law or of people’s rights.
Public Sector Equality Duty (PSED) compliance
We will deliver against our PSED strategy, provide advice and guidance to duty bearers and deliver activity to ensure compliance.
Work will include:
monitoring compliance with specific targeted public authorities or sectors, including a comprehensive review of Scottish listed public authorities, a review of central government departments and a deep dive into Wales local authority Equality Impact Assessment (EIA) practice
influencing and advising governments and public bodies, including our work to support the Scottish Government review of PSED assessment of publications by colleges and universities and advice to Wales’ tertiary education regulator on its new regulatory conditions
driving improvement and removing barriers to compliance through interventions such as production of case studies and other PSED resources
Human rights monitoring
We will continue to develop and implement our Human Rights Tracker tool, provide input to international human rights reviews and promote human rights responsibilities with the aim of building internal and external stakeholder knowledge and engagement.
Work will include:
developing and regularly updating our Human Rights Tracker tool for holding governments accountable for implementing their international human rights obligations - we will further develop the technical capability of our tracker and migrate it to our corporate website and we will draft assessments of UK and Welsh government action in relation to recommendations published in 2024 to 25
contributing to the cycle of treaty reviews as required and providing analysis relating to the delivery of international human rights obligations by governments - the cycle of treaty reviews is determined by the UN and we will contribute to each as it arises
supporting stakeholders in civil society organisations to engage effectively with the international human rights system
engaging with the development of new international human rights standards as required - we will also continue to hold nations within our remit to account for compliance with their treaty and convention obligations
Equality and Human Rights Monitor
We last published our Equality and Human Rights Monitor in November 2023. We have a requirement to publish an update every five years and aim to use the Monitor as a tool for gathering and presenting evidence, intelligence and insights on a more frequent basis.
During 2025 to 2026 we will plan for the next iteration of our Equality and Human Rights Monitor, build internal skills with data and evidence and evolve how we use data, evidence and intelligence.
Gender pay gap reporting
Monitoring compliance with gender pay gap reporting is one of our core responsibilities. We will continue with our core monitoring programme and build on evaluation we have undertaken about its usage and the quality of the data produced by organisations in order to strengthen how the information is used to drive improved equality.
Website accessibility
Monitoring compliance for website accessibility is one of our core responsibilities. Public sector websites and mobile apps must be compliant with the Public Sector Bodies (websites and Mobile Applications) Accessibility Regulations 2018 and the Equality Act 2010.
We will continue to work closely with the Government Digital Service (GDS). GDS routinely monitor the websites and mobile apps of public sector bodies, sending them reports about non-compliant elements and requesting that those issues are fixed. If a public body does not ‘fix’ the issues it highlights, GDS can pass their name to the EHRC.
Refreshing and developing our core guidance and codes of practice
Our guidance is a key element of our support to both public and private sector organisations to ensure that they adhere to the requirements of the Equality Act 2010 and human rights obligations.
Our ability to influence and support organisations through our codes and guidance should result in fewer breaches and less need for intervention through compliance, enforcement and litigation powers.
Work will include:
identifying priority guidance for updates, which will include guidance that references sensitive and difficult balancing of rights issues, such as sex and gender
building on our work last year to develop an efficient and forward-looking system to manage appropriate updates to our guidance
Enforcement and litigation activity
We will continue to deliver enforcement and litigation activity related to our core programme of work. This will include:
as necessary, enforcement of the Gender Pay Gap Information Regulations, Public Sector Bodies Accessibility Regulations and breaches of the Equality Act 2010
continuing to act as a prescribed body for whistleblowing in relation to equality and human rights
appropriate work to take account of the sexual harassment preventative duty, following changes to the law made by the Worker Protection Act 2023
Pillar Two: Agile response to equality and human rights risks and opportunities
We will act in a way that is both strategic and agile. We will prioritise our work carefully to address the most significant and urgent threats to equality and human rights. We will robustly challenge unlawful policies, practices and behaviour across our remit, through our regulatory tools, including our legal and enforcement powers.
We have designed our agile and responsive pillar as a way to prioritise our work carefully and ensure we are addressing the most significant and urgent threats to equality and human rights.
We will take evidence-driven decisions and consider how to make the most of our regulatory tools, including our legal and enforcement powers. We will use a range of interventions including restating the law, clarification of duties and publicising breaches through to full-scale enforcement activity, with consideration given to proportionality and impact.
As much of the work under Pillar Two will be responsive to emerging issues, we will plan for delivery more frequently. We will make use of the structures developed within our Regulatory Hub to triage, prioritise and deploy the most effective resources for delivery in relation to each issue identified.
Quarterly business plan updates will ensure that resources are effectively balanced to this area of work when they are needed and that we can plan for as much activity as possible throughout the year.
Much of the work that will be delivered under this pillar is not yet identified but we expect to respond throughout the year to issues such as the following:
finalising and publishing our code of practice for services, public functions and associations
reviewing our technical guidance for schools in England, Scotland and Wales
advising about the implications of implementing the socioeconomic duty in England, as proposed through legislation
continuing work with the Department for Work and Pensions in respect of our Section 20 investigation and Section 31 assessment
providing advice, guidance and support to organisations that may be at risk of being non-compliant with their duties or breaching the Equality Act 2010
providing support to ongoing litigation cases and identifying opportunities to clarify the law, including through new litigation
Pillar Three: Co-ordinated programmes of action focused on entrenched equality and human rights challenges
Through our long-term and focused programmes, we are seeking to contribute to a measurable and significant improvement in people’s experience of equalities and human rights.
For 2025 to 2028 we have identified three priority areas. Over the course of the strategic plan, we may choose to shift our priorities or develop new programmes in response to changes in the law or in society.
For 2025 to 2026 we will develop and commence delivery against our planned programmes. This will include discovery work to define the scope and reach of each programme to ensure that they remain effective and manageable.
We will refine the underpinning evidence, anticipated impact and deliverables for each programme. We aim to review and update our deliverables and progress towards impact on a quarterly basis to ensure that we stay on track.
Each of the programmes is at a different stage of development:
Programme 1: Tackling harassment, discrimination and victimisation in the uniformed services has been delivering for the past year.
Programme 2: Clarifying the law and supporting effective responses to balance of rights, including freedom of expression will be informed by work from the last strategic plan period.
Programme 3: Strengthening active participation in society by addressing barriers to public services. This will also build on some of the more responsive work we have delivered over the course of the past three years and consider issues such as access to transport for older and disabled people - we will start by scoping possible interventions, initially in the transport sector.
Programme 1: Tackling harassment, discrimination and victimisation in the uniformed services
Racial and sexual harassment, discrimination and victimisation remain entrenched in the workplaces of the fire and police services and the armed forces, despite previous critical reports.
We will further deliver against work we have planned and commenced in 2024 to 2025. This will include:
improving data through training and guidance
working with other regulators by holding roundtable discussions and agreeing action plans with other organisations
convening our equality exchange events for uniformed services to facilitate discussion about the best ways to tackle discrimination and harassment
providing PSED implementation support, for example through our improvement project with Police Scotland and the Scottish Police Authority
Through this work, we will reduce discrimination, victimisation and harassment for employees in those services and improve their work environments.
Programme 2: Clarifying the law and supporting effective responses to balance of rights, including freedom of expression
We will play an authoritative, impartial role in clarifying the law and in advising how to shape the law in a way that respects everyone’s rights.
We will select a small number of issues to focus on, such as freedom of expression and the interaction between the protected characteristics of sex and gender reassignment.
Through this programme, we will aim to foster wider respect for, and enjoyment of, human rights.
Programme 3: Strengthening active participation in society by addressing barriers to public services
Services such as public transport are important to enable people to participate actively in society. However, for many protected characteristic groups, there are significant barriers to accessing these services. For example, older and disabled people can face barriers when accessing rail or bus travel, and digital delivery can present barriers for those who are digitally excluded.
We will start by researching and scoping possible interventions to ensure we target our actions effectively. We will then consider which of our regulatory tools will be valuable in tackling the issues we identify, and work with individuals and duty bearers so they understand their rights and obligations.
We will also work closely with relevant service providers to reduce barriers and hold them to account when they act unlawfully.
Strengthening our organisation
Over the last strategic plan period, we improved our approaches to how we work through our estates and ICT. We developed the skills, knowledge and experience of our workforce and improved our governance, decision making and accountability structures.
We want to continue with this important work to increase our productivity and use public money in the most economic, effective and efficient way.
As we do not anticipate any significant increase in our budget for 2025 to 2026, we know that we will need to continue work to improve our efficiency, ensuring that we can make the best use of our people and taking opportunities to use technology to strengthen our regulatory and corporate delivery.
New ways of working
Our first priority in 2025 to 2026 is to embed the updates to our ways of working that have been identified in the strategic plan to ensure that the organisation is positioned to deliver the strongest possible outcomes for the public, within the limits of its budget.
This will include the development of robust prioritisation and deployment mechanisms for the work we deliver under Pillar Two.
We worked hard in 2024 to 2025 to develop our strategic plan and to prepare for its implementation. We will now seek to embed our new approaches and ensure that our people feel well equipped to deliver effectively.
This will include improvements to our systems and exploring opportunities to invest in artificial intelligence-based technology that can support our work.
Paris Principles compliance
Our accreditation as an ‘A status’ NHRI was renewed in October 2022 as part of a review by the Global Alliance of National Human Rights Institutions Sub-Committee on Accreditation. As part of this review, the SCA made seven recommendations to support our future compliance with the Paris Principles. We will continue our activity to make progress against these recommendations during 2025 to 2026.
Learning and development
In 2025 to 2026, we will further strengthen the EHRC to be an agile, independent and authoritative regulator. We will continue to invest in our people, management and leadership both generally and in specialist areas such as legal and compliance. This will include how we ensure that everyone has access to the training and development that they may need, or request, to be effective in their roles. This will enable us to be more responsive and to target our delivery even more effectively.
Tools and systems
We will start a detailed review of tools and systems so that everyone is supported to do their job well. This will include further technology improvements and using our offices in the most effective way.
In our estates and approaches we will seek to ensure positive workplace environments and working practices that enable everyone to give of their best and feel rewarded and valued.
We will also start early exploration of how we might use artificial intelligence responsibly to improve our own efficiency and effectiveness.
Prioritisation, delivery and reporting
We will continue to deliver as one organisation across our geographical boundaries, using a range of our powers.
As we focus on delivering our core work, responsive activity and longer-term programmes we will further refine our prioritisation, delivery and reporting mechanisms. This will ensure that we deploy our resources in ways that maximise our potential for impact and assess where we are achieving that impact.
We will invest in systems and processes that support us to be agile in redirecting resources if priorities change. We will develop our people’s skills so that they can recognise and grasp opportunities when they emerge and work across the range of our activities.
We will build on our gathering and use of data to improve our understanding of equality and human rights issues. This will further inform how we should respond to long-term and emerging issues.
Footnotes
Page updates
Published:
18 December 2025
Last updated:
18 December 2025