Equality and human rights mainstreaming: equality impact assessment

Annex B: Equality and Human Rights Mainstreaming Action Plan

Title of policy

Equality and Human Rights Mainstreaming Action Plan

Directorate: Equality, Inclusion and Human Rights Division: Mainstreaming & Inclusion Division Team: Mainstreaming Accountability Team

Summary of aims

The Mainstreaming Action Plan (MAP) aims to bring together in one place the wide range of work taking place across the Scottish Government to strengthen its systems and processes to embed equality, inclusion, and human rights into everything it does. The Action Plan intends to act as a unifying document that strengthens leadership, coordination, and accountability, ensuring that mainstreaming is not viewed as a single action or process, but as a continuous, system-wide commitment.

The Action Plan aims to increase transparency and accountability for the Scottish Government’s equality and human rights commitments. The MAP is intended to be an evolving document, updated annually to reflect progress and learning. Each annual update aims to provide a transparent account of progress against existing actions.

Executive summary

This EQIA aims to assess the introduction of the Mainstreaming Action Plan as a strategic framework, rather than assessing individual actions. Findings confirm that, provided accessibility commitments are delivered, the Plan creates no negative or discriminatory impacts. As a result of findings and mitigating action, positive impacts were identified across protected characteristic groups, particularly for older people, disabled people, minority ethnic groups and those with lower literacy levels, and women who have caring responsibilities, who are most at risk of exclusion.

As a direct result of the EQIA:

• Accessibility measures have been embedded (Easy Read, BSL summaries, paper copies and translated summaries on request)
• Inclusive and neutral language has been adopted throughout.
• The document uses plain English to remove barriers.
• A specific action has been included in the Action Plan which commits Government to developing and publishing a governance framework and new monitoring process by summer 2026 to strengthen accountability.

The EQIA concludes that the Plan will improve transparency, promote equal opportunity, and foster good relations across diverse communities.

Background

As part of the Programme for Government 2025-26^[14], the Scottish Government committed to publishing “our mainstreaming framework which will include an Action Plan and toolkit, setting out practical steps to achieve this ambition.”

This Action Plan brings together for the first time, in one place, a wide range of mainstreaming actions from across the organisation. The actions are focused on embedding equality and human rights in how we make and deliver decisions. By publishing them together, we aim to:

• Increase transparency and accountability by setting out clearly what has been committed to, and how progress will be measured and reported.
• Provide leadership and set an example of best practice for other public bodies, demonstrating how a systematic approach to mainstreaming can drive change across government and society.

In total, this version of the Action Plan includes 61 actions, each linked to one of the six key drivers of the Mainstreaming Strategy.

The scope of the EQIA

This EQIA aims to assess the introduction of the Mainstreaming Action Plan as a strategic framework, rather than assessing individual actions. The MAP does not introduce new individual policies or actions, with the exception of a small number of actions including Action 1 which commits to developing and publishing a Governance Framework for the Action Plan by summer 2026. Instead, it brings together existing actions that strengthen systems and processes to embed equality and human rights across the Scottish Government into a single, coherent framework. By doing so, it creates an opportunity to assess how effectively mainstreaming operates at an organisational level, identifying both areas of strength and areas for improvement.

Responsibility for completing equality impact assessments for individual policies and actions included in the MAP will remain with the relevant policy teams.

The EQIA aims to consider:

• How protected characteristic groups can access the Plan, including related information or opportunities to influence future iterations;
• How the Plan may support the reduction of inequalities across government systems and decision-making; and
• How the MAP can promote a culture of accountability, transparency, and continuous improvement within Government.

This EQIA also recognises that individuals often hold multiple, overlapping identities that shape how they experience inequality and discrimination. For example, a disabled woman from a minority ethnic background may face combined barriers.

All protected characteristics were considered: age, disability, sex, pregnancy and maternity, gender reassignment, sexual orientation, race, and religion or belief. Marriage and civil partnerships was screened out as it is not relevant to this policy area.

The assessment applied the three elements of the PSED: eliminating discrimination, advancing equality, and fostering good relations.

Key Findings

Age

Evidence:

We know that older people are more likely to experience social isolation, digital exclusion, and long-term health conditions, while younger people face higher unemployment, insecure work, and reduced political participation. These inequalities can be compounded by other factors such as ethnicity, disability, or caring responsibilities.

Younger and older people face distinct barriers to opportunity. Younger people are more likely to be unemployed, while older people may experience reduced independence due to health conditions or digital exclusion. These challenges can limit access to services, participation, and economic security.

Action and impacts:

The Action Plan will be published in various formats: Providing materials in accessible formats—such as HTML, print, Easy Read and BSL ensures that people of all ages can engage with and understand the MAP. Will we also have hard copies on request.

The Action Plan includes a range of actions to strengthen the policy development process to address these inequalities. This includes commitments to inclusive communication, improved data collection, and lived experience participation. For example, actions to embed learning from digital inclusion programmes and improve the equality evidence base will help ensure that age-related barriers are better understood and addressed in future policy development.

Disability

Evidence:

We know that there are lower levels of internet use for disabled adults; disabled minority ethnic workers in face multiple barriers, particularly language or communication barriers that limit access to support and information. We also know that disabled people in deprived areas are more likely to live in poverty, experience digital exclusion and reduced access to public services.

Disabled people in Scotland face significant barriers to opportunity, including lower employment rates, digital exclusion, limited transport access, and reduced access to public services. These challenges are often compounded by intersectional factors such as poverty, ethnicity, and gender, which can further restrict participation and progression.

Action and impacts:

We have ensured that information on the Mainstreaming Action Plan is available in accessible formats. Providing materials in formats such as HTML, print, Easy Read and other accessible versions (including BSL and paper copies where appropriate) will help ensure that everyone—across all protected characteristics—can engage with and understand the Mainstreaming Action Plan. This approach supports inclusive communication and helps reduce barriers to participation and feedback.

The MAP includes a range of actions to strengthen the policy development process to address these inequalities. For example, strengthening disability competence within the Scottish Government and facilitating a Cabinet Takeover for disabled people. The MAP commits to broader improvements in inclusive communication, lived experience participation, and equality data collection. These actions will help ensure disabled people can access information, influence decision-making, and benefit from equality policy on an equal basis.

Accessible formats and engagement with equality organisations enable the needs of disabled people to shape and scrutinise the MAP equally.

Sex

Evidence:

Women are statistically more likely to have unpaid caring responsibilities and to work part-time, which can limit their ability to engage with lengthy or technical material. We also recognise that women—particularly those who are disabled or from minority ethnic backgrounds—face compounded disadvantage, including lower progression.

Action and impacts:

To advance equality of access, the use of plain English summaries and accessible formats supports equal access and helps remove barriers to participation.

The Action Plan includes a range of actions that aim to strengthen the policy development process to address inequalities based on sex, such as improving the evidence base on gender and intersectionality, extending pay gap reporting to include ethnicity and disability, and applying an intersectional lens to care reform and participatory processes.

Pregnancy and maternity

Evidence:

People who are pregnant or returning from maternity leave often face barriers to full participation in public life and employment, including reduced flexibility, time pressures, and limited access to progression opportunities. These challenges are often compounded by a lack of accessible or digestible information.

Action and impacts:

The MAP supports equality of opportunity by committing to inclusive communication practices, including the provision of materials in a range of accessible formats. It also includes actions that aim to strengthen the policy development process to improve participatory processes, embed lived experience in decision-making, and promote workplace inclusion—each of which can help remove barriers for people balancing pregnancy or early parenthood.

Gender reassignment

Evidence:

Trans people in Scotland continue to face inequalities, including discrimination in public services, long waiting times for gender identity healthcare, and higher rates of mental health issues and social exclusion. These challenges are often compounded by other protected characteristics such as disability or ethnicity.

Action and impacts:

The MAP includes a range of actions that support the elimination of discrimination through inclusive communication and strengthened engagement with equality groups. This includes commitments to develop inclusive communications guidance, improve the use of equality data, and embed lived experience in policy development.

The MAP uses inclusive language and avoids assumptions about gender identity, helping to reduce the risk of reinforcing binary or exclusionary norms. This EQIA identifies the importance of embedding inclusive communication practices across all materials and ensuring that future iterations of the MAP and its governance framework continue to strengthen trans inclusion across government.

Sexual orientation

Evidence:

LGB people are more likely to experience discrimination in public spaces, hate crime, and a lower sense of belonging in their communities. Without careful attention, public documents and strategies can unintentionally reinforce heteronormative assumptions or exclude diverse family structures.

LGB people are more likely to report poorer mental health, lower community belonging, and higher rates of discrimination. These factors can reduce confidence in engaging with public services or participating in policy processes.

Action and impacts:

The MAP supports equality of opportunity by ensuring that its content is inclusive and accessible to people of all sexual orientations. This includes the use of inclusive language, the avoidance of assumptions about family or relationship structures, and the provision of materials in accessible formats such as HTML, Easy Read, and BSL where appropriate.

The MAP also includes actions that aim to strengthen the policy development process through improving lived experience participation, strengthening equality data collection, and enhancing Government competence in equality and human rights. These actions will help ensure that LGB people are not only considered in the development of equality actions but are actively involved in shaping them.

Race

Evidence:

Minority ethnic communities in Scotland face persistent inequalities, including lower employment rates, higher in-work poverty, and greater exposure to discrimination in public services and civic life. These challenges are often compounded by language barriers, under-representation, and a lack of trust in institutions.

Minority ethnic people in Scotland face a 10.2 percentage point employment gap compared to White people, are more likely to live in overcrowded housing, and experience higher rates of in-work poverty. These structural inequalities limit opportunities for full participation in society and public life.

Action and impacts:

The MAP includes a range of actions that aim to strengthen the policy development process to address these inequalities and support the elimination of racial discrimination. This includes actions to strengthen anti-racism leadership, improve the collection and use of ethnicity data, and embed lived experience in policy development. For example, actions such as the launch of the Anti-Racism Observatory, improvements to ethnicity pay gap reporting, and enhanced participatory processes all contribute to tackling systemic barriers.

The MAP also supports inclusive communication practices, including the use of plain English and offering translated versions when requested, which help reduce language-based exclusion and improve access to information for people whose first language is not English.

We have ensured that information on the Mainstreaming Action Plan is available in accessible formats. Providing materials in formats such as HTML, print, Easy Read and other accessible versions (including BSL and paper copies where appropriate) will help ensure that everyone—across all protected characteristics—can engage with and understand the Mainstreaming Action Plan. This approach supports inclusive communication and helps reduce barriers to participation and feedback.

Religion or belief

Evidence:

We know that people from minority faith groups—including Muslim, Sikh, and Jewish communities—report higher levels of discrimination and hate crime exposure in Scotland. These groups also perceive under-representation in civic and public life, and when combined with ethnicity or socio-economic disadvantage, the risk of exclusion increases.

Action and impacts:

The Action Plan includes range of actions that strengthens the policy development process to support the elimination of discrimination for people of all faiths and beliefs. This includes actions to improve religious literacy across government, strengthen the equality evidence base on faith and belief, and embed lived experience in policy development. These actions aim to ensure that officials and decision-makers have a more nuanced understanding of Scotland’s diverse faith communities and are better equipped to reflect their needs in policy and service design.

The MAP also uses neutral, respectful language that is inclusive of all faiths and of those with no religion.