Counting Every Story: Intersectional Gender Data for Inclusive Policy-Making

Majida Kassem, Freya Phillips National Scholar, Commission on the Status of Women 2023 Fellow

Executive Summary

This paper proposes an Inclusive Gender Reporting Program to address the limited frameworks in Australia that fail to capture the diverse experiences of women in the workplace. The program would integrate intersectional perspectives into the Workplace Gender Equality Agency (WGEA) reporting structure, funded through the "Intersectional Representation Fund for Gender Equality." An intersectional approach reveals how multiple forms of discrimination—based on ethnicity, age, disability, or socio-economic status—interact to shape unequal workplace outcomes for women. (Women’s Legal Service Victoria, 2022). 

Economically, this has measurable consequences. A 2022 report by the Diversity Council Australia and McKinsey & Company estimated workplace exclusion and underutilisation of culturally diverse women could cost the Australian economy up to $8 billion annually in lost productivity and leadership potential. Failing to address intersectional gaps also hinders progress on closing the national gender pay gap, which remains at 13% but is significantly higher when disaggregated by race or disability (WGEA, 2023). 

The proposal includes expanding the WGEA Gender Equality Reporting Tool to include mandatory intersectional questions. Estimated initial setup costs are $2 million, with a $1 million resource reallocation over five years. This could be rolled out over a two-year period, starting with large employers before expanding to all eligible organisations. Success will be measured through increased data collection, practical policy impacts, and broader discourse shifts. Key challenges include protecting privacy, ensuring data quality, and maintaining political support. By integrating factors such as ethnicity, disability, age, and socio-economic status, the initiative would equip government and industry with the evidence needed to design more targeted, effective gender equality policies.

Problem Identification

Australia's public policy lacks a comprehensive intersectional approach, despite its diverse and multicultural context. 

In workplaces, women with intersecting marginalised identities face compounded disadvantages, including pay inequity and limited advancement opportunities (WGEA, 2023). Australia's gender data frameworks fail to capture these complexities, limiting policy effectiveness. Aboriginal and Torres Strait Islander women, for example, have a lower workforce participation rate (51.5%) than non-Indigenous women (WGEA, 2023), while 65% of Culturally and Racially Marginalised (CARM) women report fewer leadership opportunities (Diversity Council Australia, 2023). 

The Workplace Gender Equality Act 2012 mandates reporting primarily through a binary gender lens, omitting key intersectional factors like First Nations heritage, cultural background, disability, and sexuality (WGEA Diversity and Inclusion Report, 2022). Without intersectional data, the experiences of 89% of women who identify with one or more diversity groups are overlooked (2021 APS Census).

Context

Background

Workplace gender inequality in Australia stems from the undervaluation of female-dominated industries, women’s underrepresentation in leadership, and disproportionate unpaid labour (CEDA, 2023).

Legal scholar Kimberlé Crenshaw introduced the concept of intersectional feminism to describe how systems of power—such as racism, sexism, classism, and ableism—interact to produce unique forms of marginalisation (Coaston, 2019). In the workplace, this means that a First Nations woman or a migrant woman with a disability may face compounding barriers not captured in gender-only analysis. Crenshaw’s framework challenges institutions to move beyond single-axis approaches and instead recognise policies failing to account for these intersections are not just incomplete but structurally unequal. Without intersectional data, public policy misrepresents the scale and nature of inequality—and therefore cannot respond effectively (Crenshaw, 1989). 

Under the Workplace Gender Equality Act 2012, non-public sector employers with 100 or more employees must submit annual reports to the Workplace Gender Equality Agency (WGEA). These include data on workforce composition, pay gaps, promotions, resignations, and policies related to gender equality, submitted via an online portal and approved by the organisation’s CEO (WGEA, 2022). 

WGEA oversees compliance, publishes annual industry benchmarks, and uses the data to inform government policy and gender equality strategies. Non-compliant organisations may be named in Parliament and are ineligible for government contracts or grants. While the framework has improved gender transparency, it treats gender as binary and lacks disaggregation by race, disability, or other identity markers—limiting its capacity to inform inclusive, intersectional policymaking.  

Australia's international obligations under the Sustainable Development Goals (SDGs) reinforce the need for intersectional approaches. SDG 5 (Gender Equality) and SDG 17.18 (Data, Monitoring, and Accountability) mandate the collection of high-quality, disaggregated data by gender, income, race, and disability (UN Women, 2022). Strengthening intersectional reporting aligns national practices with these global commitments.

In the Australian financial and insurance services sector, the Workplace Gender Equality Agency reported a 26.1% median total remuneration gender pay gap in 2022–23; the highest among all industries and well above the national average (WGEA, 2024). A 2024 Reuters analysis further confirmed that finance continues to exhibit one of the largest gender pay gaps in Australia (Reuters, 2024). Meanwhile, healthcare remains a highly feminised workforce with persistent occupational segregation, making both sectors ideal candidates for targeted capability-building interventions

Case Study - Deepening the Intersectional Lens: insights from Canadian GBA+

In 2011, the Canadian government introduced GBA+ (Gender-Based Analysis Plus), expanding gender analysis to include intersecting factors such as race, ethnicity, disability, and age. GBA+ is now a mandatory step in the development of federal policies, programs, and budgets. Its implementation has resulted in more inclusive national budgets, including the allocation of $100 million over five years (2018–2023) for a federal Strategy to Prevent and Address Gender-Based Violence, with specific supports for Indigenous women, LGBTQ2+ communities, and women with disabilities (Government of Canada, 2018). The 2021 Canadian federal budget also included $30 billion over five years to support universal childcare, justified in part through GBA+ analysis that showed disproportionate impacts on racialised and low-income women during COVID-19 (Government of Canada, 2021). 

These outcomes demonstrate how integrating intersectional analysis into policymaking can result in more equitable resource allocation and targeted structural reform. 

By comparison, Australia already has the foundational infrastructure to implement similar reforms. The Workplace Gender Equality Act 2012 mandates annual reporting for employers with 100+ staff, and WGEA’s digital reporting portal provides a centralised, scalable platform. However, unlike GBA+, the current framework lacks mandated disaggregation by identity, limiting its ability to guide intersectional reforms. 

Even so, WGEA reporting has influenced public policy. Data from its reports informed the 2022 national gender pay gap audit and supported the Workplace Gender Equality Amendment (Closing the Gender Pay Gap) Act 2023, which now requires public disclosure of employer pay gaps—an important step towards workplace transparency and reform (WGEA, 2023). Expanding the framework to include intersectional data would build on this momentum and enable government and industry to respond to overlapping inequalities with the same precision. 

Policy Options

1. Develop and deliver targeted intersectional gender data training 

   
   

This option involves the federal government funding professional development programs on intersectional data collection for HR, compliance, and diversity officers in WGEA-reporting organisations. Training could be commissioned through grants or procurement contracts with universities, TAFEs, or accredited training providers. While the government cannot mandate delivery through independent institutions, it can design nationally consistent course criteria and offer financial incentives for uptake. This option could be rolled out within one year, starting with priority sectors such as finance and healthcare, where gender inequalities are well-documented and where early uptake could set a precedent for other industries.

This option serves as a low-cost entry point to improving organisational readiness and awareness of intersectional gender data practices. It would particularly benefit larger organisations with existing capacity to engage in training initiatives. However, its voluntary nature means uptake could be uneven across sectors and organisations, limiting national reach. More importantly, while the initiative builds workforce capability, it does not enact any direct policy change or fill structural data gaps in current reporting frameworks. Without binding requirements, this option risks delaying more comprehensive regulatory reforms that are necessary for national consistency.

2. Develop and implement a mandatory intersectional gender reporting framework

   
   

Australia should revise WGEA's reporting model by mandating 8–10  additional questions that address key areas of intersectional gender inequality. These would include: the presence of diversity and inclusion policies explicitly covering First Nations status, disability, race, sexuality, and socio-economic background; gender pay gaps disaggregated by intersecting identities; the representation of marginalised groups in leadership and technical roles; targeted programs for the career progression of marginalised women; and the use of intersectional data in internal policy development and evaluation. To ensure consistent responses across organisations, these additions should use standardised formats such as tick-boxes or structured short-answer responses.

Responsibility for designing and implementing the revised reporting model would lie with the Department of the Prime Minister and Cabinet, which oversees WGEA, in collaboration with a newly established Specialised Intersectional Gender Reporting Committee. This committee would include representatives from WGEA, academic experts, and community sector stakeholders to ensure that the reform is both evidence-based and community-informed. The new reporting requirements would be introduced as a regulatory reform and phased in over two years, initially targeting large employers and gradually extending to all WGEA-reporting entities.

This option builds on the existing WGEA infrastructure, making it a scalable and measurable solution with clear enforcement mechanisms already in place. It would provide policymakers and researchers with higher-quality data and better visibility into the experiences of marginalised groups, thereby informing more inclusive workplace policies. However, this reform would involve a higher cost and compliance burden for employers and may require considerable political capital to pass. Moreover, it would not capture data from smaller employers with fewer than 100 staff, who are currently excluded from WGEA’s reporting obligations.

3. Require intersectional data collection through government procurement contracts

   
   

Under this model, the federal government would require all companies bidding for Commonwealth procurement contracts above a designated financial threshold to report on their workforce diversity using an intersectional lens. This requirement could be implemented through existing digital supplier platforms such as AusTender, and would align with Australia’s broader responsible business conduct frameworks, including the Commonwealth Procurement Rules (CPRs), the OECD Guidelines for Multinational Enterprises, and the National Action Plan on Business and Human Rights. By embedding diversity reporting into procurement policy, the government would leverage its role as a major purchaser to incentivise more inclusive employment practices among large private sector firms.

This option would primarily benefit the government, by generating valuable intersectional workforce data from suppliers, while also creating market incentives for large businesses to improve transparency and diversity outcomes. It targets high-impact companies, those already engaged in major government contracts, without the need for new legislative infrastructure. However, this approach excludes smaller businesses and sectors not engaged in government procurement, resulting in partial coverage and no direct mandate across the wider labour market. Additionally, while it promotes good practice through market-based incentives, it does not impose binding diversity policy reforms across all sectors.

4. Integrate intersectional data collection into the ABS Census and national workforce surveys

   
   

   This option would involve the Australian Bureau of Statistics (ABS) incorporating standardised questions on gender identity, race, disability, and workplace experiences into the five-yearly Census and routine national workforce surveys, such as the Labour Force Survey and the Survey of Income and Housing. By doing so, it would enable population-wide, disaggregated data collection across multiple intersecting identities and employment conditions. The inclusion of such questions would provide national-level benchmarking on intersectional inequalities and help to identify systemic disparities across industries, regions, and demographic groups. These datasets would also serve to complement WGEA-collected organisational data by offering a macro-level perspective on workforce trends.

   This option would significantly benefit researchers and policymakers, enabling the development of evidence-based strategies grounded in robust national insights. However, it would be slower to implement, given the ABS’s survey cycles and approval processes, and the Census is only conducted every five years, limiting the system’s short-term responsiveness. Furthermore, while this option strengthens national-level data infrastructure, it does not provide organisation-level data, meaning it cannot capture specific employer practices or outcomes in real time.

Policy Recommendation

This paper recommends Option 2 - mandating intersectional gender data reporting under the WGEA framework. The Australian Government should require all non-public sector employers with 100 or more employees to annually report disaggregated workforce data, strengthening existing WGEA reporting obligations and ensuring inclusive metrics become a national standard. Mandatory reporting would ensure the systematic inclusion of marginalised experiences and provide consistent, high-quality data to inform gender equity policies. 

Unlike Option 1, which supports voluntary training and capability-building, this recommendation enacts legal obligations through legislative reform. Revising WGEA reporting questions alone is not sufficient; Questions 1.10 and 1.11 are currently voluntary, and even if revised through regulation, they do not compel organisations to collect or report intersectional data from employees. Legislative amendments to the Workplace Gender Equality Act 2012 are therefore necessary to extend employer responsibilities and formalise reporting requirements. This reform would be rolled out over a two-year period, beginning with larger employers and expanding to all relevant organisations by the second reporting cycle. 

Mechanism for Implementation

This reform would be enacted through amendments to the Workplace Gender Equality Act 2012, expanding the scope of employer reporting obligations to include intersectional data points across dimensions such as race, age, disability, sexuality, and First Nations identity. WGEA would administer the data collection and oversee compliance. 

Consultation with employer and industry bodies such as the Australian Industry Group (Ai Group), community advocates including the Equality Rights Alliance, and diversity experts from organisations like the Multicultural Centre for Women’s Health (MCWH) would guide implementation design and ensure alignment with sector capabilities. These groups can provide technical feedback on feasibility, help identify potential sector-specific barriers, and support employer outreach and awareness during implementation.

Costs

The estimated cost of implementing mandatory intersectional data reporting is $7.7 million over five years. This includes development, rollout, enforcement, and support measures. The program would be funded primarily through the Department of the Prime Minister and Cabinet’s Office for Women, supplemented by targeted WGEA operational grants. 

Breakdown: 

● Stakeholder Engagement – $1 million 

● Data Integration Technology – $1.3 million 

● Guideline Development – $800,000 

● Training Delivery – $1.5 million 

● Audits and Independent Reviews – $1 million 

● Small Business Subsidies – $2 million 

For $7.7 million over five years, this reform would generate nationally consistent, intersectional workforce data — enabling more equitable policies and strengthening accountability across thousands of Australian workplaces.

Success Measurement

Success will be gauged through KPIs set by WGEA, including the proportion of organisations submitting intersectional data, improvements in data quality, and reported policy changes linked to reporting insights. Independent evaluations every two years will ensure program effectiveness and guide adjustments. WGEA will contract external evaluators to conduct independent reviews every two years, assess overall effectiveness, and guide iterative adjustments. 

Limitations

One limitation of the proposed reform is the potential financial and administrative burden on smaller organisations, which may lack the infrastructure or expertise to implement detailed intersectional reporting. To mitigate this, the government could provide subsidised reporting tools, free training modules, and template-based submission formats to streamline participation and reduce resource strain. 

Another concern relates to employee privacy and data sensitivity. Workers may be hesitant to disclose information about their race, sexuality, disability, or gender identity, especially in smaller teams where anonymity feels less assured. To address this, WGEA will require only de-identified, aggregate-level reporting, and ensure that all identity-related questions include optional response fields, respecting individual comfort and consent. 

Finally, there is a risk of superficial compliance, where organisations provide basic data without engaging with its implications. To prevent this, reporting requirements will include qualitative assessments, such as short reflective statements on how organisations have used their data to inform internal policies or initiatives, and periodic audits will evaluate the meaningfulness of engagement beyond raw numbers.

Risks

Superficial Compliance

There is a risk that some organisations may adopt a tick-box approach, meeting the minimum reporting requirements without taking meaningful internal action to address inequality. This is especially likely if there are no clear incentives for high performance or consequences for underperformance. Larger employers with more resources may prioritise optics over substance, while smaller reporting entities may lack the expertise to interpret and act on intersectional data effectively.

To address this, WGEA will publish compliance scores and transparency metrics, linking outcomes to public employer scorecards that highlight organisations demonstrating leadership or failing to meet expectations. Tailored feedback will be provided to non-compliant organisations, and sector-specific benchmarking will allow for peer comparison. Over time, this reputational accountability, combined with guidance and follow-up support, can encourage continuous improvement beyond basic compliance.

Cultural Resistance

Intersectional data reporting may face cultural or ideological resistance, especially in industries with limited diversity or politically conservative leadership. Some stakeholders may view the reform as ideologically driven rather than evidence-based, leading to disengagement or public opposition.

To manage this risk, the reform will be strategically framed as a tool for business improvement, emphasising its link to organisational performance, innovation, talent retention, and compliance with global Environmental, Social and Governance (ESG) trends. Communication materials will focus on the economic case for inclusion and will avoid polarising language. In parallel, proactive engagement with industry bodies, unions, and professional associations will be used to secure early champions and reduce politicisation. Training and outreach will also include case studies that highlight real-world benefits of intersectional workforce insights.

Economic Risks

The introduction of additional regulatory oversight may trigger pushback from employers, industry groups, and peak business bodies, particularly if it is perceived as introducing high compliance costs or administrative burden. This could stall implementation or reduce employer participation, especially among mid-sized firms who lack dedicated diversity or compliance teams.

To mitigate this, the reform will be designed for low-cost integration into existing platforms such as WGEA, AusTender, and ABS systems, thereby minimising duplication and IT costs. It will also include targeted support, such as templates, step-by-step reporting guides, and sector-specific implementation toolkits. A phased rollout starting with large employers, who already have compliance infrastructure in place, will allow time to build best practices and refine systems before expanding the scope. Ongoing consultation will ensure that efficiency and scalability remain central to the reform's economic viability.

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