First Minister's National Advisory Council on Women and Girls First Phase Two Report: Scottish Government Response

Accountability Culture

Openness, transparency and accountability are integral values in the Scottish Government that all officials are expected to demonstrate.

Developing accountability and transparency is also a key driver for change within the Mainstreaming Strategy which supports the Scottish Government, and wider Scottish Public Sector, to focus on mainstreaming equality and human rights.

Since 2016, Scotland has been a member of the Open Government Partnership (OGP). Through the OGP, we have produced two Action Plans focusing on the promotion of transparency, participation, inclusivity and accountability.

Calls to Action: Capacity building and external scrutiny

1. Scottish Government officials should be supported through capacity building on accountability processes of this kind (i.e. scrutiny of work by external advisory groups) and encouraged how to respond to external scrutiny through expert groups, of all levels, with candid responses which prioritise learning and policy improvement.

The Scottish Government accepts this Call to Action.

Being open and transparent is central to the Scottish Government values of integrity, inclusivity, collaboration, innovation and kindness. External scrutiny supports and challenges us to improve our work and delivery, to ensure that we are creating and delivering the best policies for the people we serve. Scottish Government officials must abide by the Civil Service Code, including our commitment to honesty and openness. Our annual In The Service of Scotland (ITSOS) event offers officials the opportunity to learn more about the principles of the Civil Service Code and the importance of integrity to our work. The Scottish Government has been a member of the Open Government Partnership since 2016, and is committed to working in collaboration with civil society to embed transparent, accountable and participatory ways of working.

However, the NACWG has been forthright in their report that officials could be more open and candid with them when discussing ongoing work in their respective policy areas. To this end, the Cabinet Secretary for Social Justice wrote in December 2024 to relevant Ministers with portfolios being scrutinised by the NACWG during the Third Focus of Scrutiny, to reiterate to their officials that when engaging with the NACWG they were expected to be candid and transparent with them.

The Scottish Government also provides training and resources on engaging with stakeholders and members of the public in an accountable and transparent way, such as the Participation Handbook. We have also produced consultation guidance for Scottish Government officials to support them when consulting the wider public. The consultation guidance is underpinned by the Gunning Principles and UK Government best practice for consultation principles, which form the foundational legal requirements for conducting engagement and consultation in an accountable and transparent manner.

In December 2025, we launched the Equality and Human Rights Mainstreaming Toolkit (Mainstreaming Toolkit) to promote knowledge and share good practice across the public sector, improving learning capacity in this area. This is an accessible online portal which includes materials to help the Scottish Government and wider public sector put equality and human rights at the heart of their work. It includes a selection of good practice resources on each of the Mainstreaming Drivers, including developing accountability and transparency.

We will continue to build on these resources and support officials to increase the transparency and accountability of their work. Work is being planned that will make further participation and Open Government training available to all staff.

Calls to Action: Standard practice for accountability and scrutiny

2. To enable a culture which supports and normalises a wide range of accountability practices, the Scottish Government should create a standard practice for relevant strategic advisory groups, taskforces or councils which includes an expectation of accountability and scrutiny of the Scottish Government as part of their remit along with an appropriately-skilled secretariat to support this work.

The Scottish Government accepts the ambition of this Call to Action.

The Scottish Government offers a wide range of training and guidance for officials through our internal training service, Pathways. This includes training on participation and engagement with stakeholders, and governance and policy delivery.

Officials across government are encouraged to engage with stakeholders to understand and address issues that people in Scotland are facing. We are clear that officials and Scottish Ministers are accountable to the people and stakeholders we work with and understand the importance of ensuring that stakeholders are supported to engage with us and hold us to account. Each area of the Scottish Government will need to engage with different stakeholders, in different ways at different times. It is important that we tailor how we engage with stakeholders to their needs and the needs of the policy area.

Our Participation Handbook is our main guide which highlights good practice in participation across government and will be used as a basis for staff training. The guide sets clear expectations for officials that engagement and participation with external groups should be meaningful, with participants informed upfront about purpose, influence and outcomes, supported by accessible, jargonfree communication and feedback on impact.

The development of the equality strategy for women and girls will provide an opportunity to further reflect and develop our approach to working collaboratively with external scrutiny bodies.

Calls to Action: Action plan for accountability and scrutiny

3. As part of the internal culture building within the Scottish Government, it is understood that senior leaders have identified five improvement priority areas to deliver “organisational change activity.” As part of this there is a focus to create an empowering and enabling culture and nurture respectful and trusting partnerships. Within these two priority areas senior leadership should embed the normalisation of effective external accountability and scrutiny on policy development and implementation. We recommend that there is a published action plan which sets out how this will be delivered and evaluated to measure success.

The Scottish Government accepts the ambition of this Call to Action.

We welcome the opportunity we have had to discuss In The Service of Scotland (ITSOS) and its central priorities to create an empowering and enabling culture and nurture respectful and trusting partnerships with members of the NACWG. ITSOS has been the organisation’s vision since 2020 and sets out the Scottish Government’s mission and values for individuals and policy areas to deliver. We have developed and are developing a range of actions to embed ITSOS and a culture of accountability across the Scottish Government, including through providing technical or professional skills as a route to improving practices.

Previous NACWG reports have referred to the role of the Civil Service professions, and the Policy Profession specifically, as one mechanism for improving individual practices across the organisation. The Policy Profession’s competency framework sets the expectation of external accountability and scrutiny as part of policy development and implementation, asking that policy professionals at every career stage engage those affected by policy, and relevant experts, throughout the policy development process.

Those expectations are included throughout the competency framework of twelve professional Standards, which covers all the activities of the policy cycle. The importance of external advice, involvement, and accountability is highlighted within the specific expectations of policy practice across the policy cycle from:

• strategy through appraisal and advice to participation (Standards 1.1, 1.2, 1.3);
• to Ministerial, Parliamentary, legal, and financial scrutiny (Standards 2.1, 2.2, 2.3);
• and in the design and governance of implementation through to evaluation (Standards 3.1, 3.2, 3.4).

As mentioned, it is an expectation that all staff have awareness and understanding of the importance of external accountability and scrutiny via the competency framework. To ensure this, the competency framework is mainstreamed across government through the professional community of practice of over 2,000 colleagues; a regular newsletter; and regular introductory events open to all staff. The competency framework is also embedded into the HR lifecycle for all policy roles in the Scottish Government; used in recruitment to select candidates and define skills required for roles; referred to in development planning and appraisal guidance; and used to develop capabilities by providing the structure and learning outcomes for a comprehensive, free, online curriculum and accompanying events programme open to all staff.

As well as setting expectations, the profession brings together the support that enables staff to meet those expectations by developing the relevant skills and knowledge through learning activities, including a comprehensive online curriculum and regular learning events. Relevant expert teams in the organisation define best practice in relation to the competency framework. Expert teams are those who oversee the relevant skills across the twelve Standards, such as Cabinet Secretariat, Ministerial private offices, and the Equality, Inclusion and Human Rights Directorate. These expert teams provide online learning resources which set out guidance and expectations, complemented by learning events they deliver to help staff develop the relevant practices through which advice and accountability are sought, such as appraisal and evaluation, working with stakeholders, and risk and corporate governance.

The Policy Profession’s learning offer is still maturing within Scottish Government and is dependent on the capacity of expert teams to develop others, so it will take some time for these expectations to translate to improved practices. However, the importance of advice and accountability are core principles that are continually reinforced in the guidance for many of the practices and processes across the policy cycle.

We have also published, in December 2025, the Equality and Human Rights Mainstreaming Strategy (Mainstreaming Strategy), which articulates a framework for action to advance the mainstreaming of equality and human rights against six key drivers. The drivers emerged clearly and consistently through stakeholder engagement, reflecting the areas where change is most needed and possible. This includes specific focus on actively and meaningfully embedding accountability and transparency into the design and implementation of policy. To support the Mainstreaming Strategy, we have published an Equality and Human Rights Mainstreaming Action Plan (Mainstreaming Action Plan) – it increases accessibility and transparency by bringing together in one place, for the first time, actions being taken across the Scottish Government to mainstream equality and human rights. We recognise that an action plan alone does not drive progress, that’s why we have, subject to the outcome of the upcoming Scottish Parliament election, committed to developing and publishing a governance framework to underpin the delivery of the Mainstreaming Action Plan this summer.

Our aim is to create a transparent framework, which reflects best practice and embeds accountability. We are exploring how we might use this framework to support accountability across wider Mainstreaming activity within the Scottish Government. For example, this could include our commitments to improve the effectiveness of the Public Sector Equality Duty (PSED) in Scotland. Officials are utilising the suggestions in the NACWG Phase Two Report to inform this work.

As mentioned previously, we are an Open Government and we will continue to build on our resources and the support offered to officials to increase transparency and accountability. Trust and Transparency is also likely to be a key theme in our upcoming next iteration of the Open Government Action Plan, which is currently being co-created with civil society and the public and is expected to be published in early 2026.

In addition to the work to support officials to provide accountability and transparency to stakeholders more broadly by the Policy Profession and Open Government, it is also our intention to embed scrutiny and accountability measures into any future equality strategy for women and girls. Subject to this government being returned after the Scottish Parliament election we will develop, with input from gender equality stakeholders, a suite of accountability mechanisms for the strategy. It is our intention that these mechanisms will provide transparency, confidence and accessible scrutiny in a range of ways to all women and girls, and the organisations which represent them.