Building Equality Policy Reporting: A Guide for Victorian Contractors

The Short Answer

The Building Equality Policy (BEP) is a Victorian Government procurement policy that sets minimum hours of work for women on publicly funded construction projects valued at $20 million or more (excluding GST). Contractors estimate project hours by occupation within 30 days of award, report the actual hours worked by women and by women apprentices, trainees and cadets every six months and at practical completion, and keep Gender Equality Action Plans up to date across the life of the project.

This guide sets out what the policy requires, who it applies to, the targets, what reporting looks like in practice, and how to set it up so the numbers hold up. Every policy fact below comes from the Victorian Government's own pages, linked in the sources at the end. If anything here differs from the current policy or your contract, the policy and your contract win.

What Is the Building Equality Policy?

The BEP came into effect on 1 January 2022 and does not apply retrospectively. It is implemented through the Victorian Social Procurement Framework, and Victorian government departments and agencies are responsible for implementing it on their projects. It asks contractors to take three actions: meet minimum hours of work for women across role types, meet a minimum for women apprentices, trainees and cadets, and maintain Gender Equality Action Plans.

For the background on why the policy was introduced, see our earlier piece on the Building Equality Policy and gender equity in construction. This guide is about the reporting.

Who Does the Building Equality Policy Apply To?

According to the BEP guidance for suppliers, the policy applies to publicly funded construction projects valued at $20 million or more (excluding GST) where the tender was released on or after 1 January 2022. It applies to projects procured by a public body or a department under Section 3 of the Financial Management Act 1994. Where a project is procured in several packages, its value is assessed on the combined value.

The BEP guidance for buyers lists what is out of scope, including:

• Projects contracted, or tenders released, before 1 January 2022
• Non-construction services such as design, operation and management
• Grants

The Building Equality Policy Targets

Every BEP target is measured in hours of work, not headcount. The policy sets these minimums:

• Action 1, trade roles: women perform at least 3% of the total estimated hours of work on the project for each trade position
• Action 1, non-trade Construction Award roles: women perform at least 7% of the total estimated hours of work on the project
• Action 1, management, supervisory and specialist roles: women perform at least 35% of the total estimated hours of work on the project
• Action 2, apprentices, trainees and cadets: women apprentices, trainees and cadets perform a minimum of 4% of the total estimated hours of work on the project
• Action 3, Gender Equality Action Plans: the contractor submits an Organisation Wide Gender Equality Action Plan and a Project Specific Gender Equality Action Plan

A few details matter for reporting. The trade target applies to each trade position, not to trades as a whole, so a project can meet 3% across all trades and still fall short in one. Off-site training hours under a training contract count towards the apprentice, trainee and cadet target. Anyone identifying as a woman is counted in the data collected for women. Trade partners are not required to complete Gender Equality Action Plan documents, but their hours still count towards Actions 1 and 2.

What Does Building Equality Policy Reporting Look Like?

The supplier guidance sets out a reporting rhythm that runs from contract award to practical completion:

1. Within 30 days of the contract being awarded: report the total estimated hours for each occupation, which establishes the targets the project reports against
2. Every 6 months and at practical completion: report the actual hours worked by each woman, and by each apprentice, trainee and cadet (Actions 1 and 2)
3. Every 6 months and at practical completion: update the Project Specific Gender Equality Action Plan
4. Every 12 months and at practical completion: update the Organisation Wide Gender Equality Action Plan

Reporting must be captured and reported at a position level, according to the staged approach to non-compliance. Departments and agencies must ensure contractors meet and report on their BEP commitments, so the contracting agency sets the exact format and the system you submit through. Check your contract for both.

What Happens If a Project Falls Short?

From 1 July 2024, non-compliance is managed using a staged approach for contracts executed on or after that date. In summary, a shortfall starts with a non-compliance notification and works towards agreed alternative appropriate obligations. Those alternatives cannot be aggregate targets and cannot fall below the Action 1 and Action 2 minimums. If no agreement is reached, the contract manager may treat it as a breach of contract. The guidance also lists placement on a register for increased compliance oversight and a formal warning from the responsible departmental Secretary or Minister among the possible responses.

The practical lesson is that the six-monthly report is not the moment to find out. A shortfall in one trade position spotted early can still be recovered through recruitment and trade partner engagement. The same shortfall found at practical completion cannot.

Recent Changes to Watch

The Victorian Government notes that the transitional compliance period has been extended, that RMIT was appointed in 2023 to evaluate the policy, and that it has committed to raising the targets and changing the action plans. At the time of writing, new target percentages and an effective date have not been published. We will update this guide when they are.

How to Set Up BEP Reporting on a Project

1. Build the occupation-level hours estimate at award, because it sets every target the project is measured against
2. Write the BEP data fields, definitions and submission timing into every trade package, since most hours are worked by trade partners
3. Collect hours by worker, gender and position monthly, so the six-monthly report is a roll-up rather than a scramble
4. Track each trade position separately against its 3% minimum, not just the trade total
5. Keep apprentice, trainee and cadet records, including off-site training hours, with evidence of the training contract
6. Keep both Gender Equality Action Plans on their own schedules, with the commitments tracked alongside the hours

How Catchment Helps With Building Equality Policy Reporting

Catchment's SocialPro module is where head contractors and their trade partners record participation hours against workforce targets. The BEP targets are set up once against your occupation-level estimate, trade partners submit hours against the same fields each month for free, and progress for every trade position, the apprentice target and the management target is visible long before the six-monthly report is due. Each figure keeps its evidence, so the report you hand the agency can be traced back to source.

If you are delivering a BEP project, book a demo and we will show how your targets and trade partner reporting would be set up.

Sources

Victorian Government, Building Equality Policy

Victorian Government, Building Equality Policy: guidance for suppliers

Victorian Government, Building Equality Policy: guidance for buyers

Victorian Government, Building Equality Policy: staged approach to non-compliance