WGEA case study: How the ACCC reduced its gender pay gap

Between 2018 and 2026, the Australian Competition and Consumer Commission gender pay gap dropped from 10.5% to just 1%.  

The Commonwealth public sector agency spoke with WGEA about their motivation to end the gender pay gap, their data-informed approach to action and how they turned their targets into business-as-usual activity.   

Peter Grey likes to think of his role at the ACCC as “the numbers guy”.

As the Australian Competition and Consumer Commission’s principal data analyst, he’s used to being elbow deep in investigations, collecting evidence on organisations suspected of doing the wrong thing.

“We are here to protect consumers and make sure that we are the good guys,” he says.

“I am very motivated by fairness and things being right.”

So when the agency decided to investigate its own gender pay gap in 2018 – and discovered men were being paid 10.5% more than women on average – it came as a shock to both Peter, and the entire agency.

“It was probably a lot higher than what we expected, given how well-structured the public service salary structures are and given wage compression in the public sector, compared to the private sector,” he says. 

“We got quite a lot of reaction. And a lot of push back from kind of different people.

“There was a lot of negative reaction, people questioning what we were doing, why we were doing it, why it even mattered.”

Data is important

Mr Grey says data has played a crucial role in the agency’s gender equality work.

“We’ve always let the data speak for itself and present it in a very neutral and objective way,” Mr Grey says.

“Data really allows you to cut through in a way that anecdotes don’t. 

“It really allows you to take a step back from sort of individual stories and have this more, complete overview, a more of a macro view of the situation. 

“It allows you to move away from individuals to the sort of overall structure of the organisation.”

Education is key

The Agency embarked on an education exercise across the agency, right up to the senior leadership, about what the gender pay gap was, says Gina Dolan, the ACCC’s general manager of people.

“When we first got that 10.5%, we engaged with all of our employees,” she says.

“We did sessions across Australia, to educate them around what is a pay gap and why we thought it was important that we measure it. 

“And we got a full spectrum of responses from employees, from those who were hugely passionate about it, to those who were wondering why we were doing this and was it an effective use of our resources and time.”

Leadership was also important, she says. 

“It was engaging with our senior leaders first, because in my experience you need that senior leadership support to really focus on strategies to reduce the pay gap. 

“We also worked with our diversity inclusion forums, our gender network, and our flexibility work group, as well as an array of others, and set up focus groups just to get perspectives from employees.”

Getting to work

The ACCC got down to work, Ms Dolan says.

“There’s a broad array of things that we needed to look at, agency-wide, and it spans from how do we recruit people into the agency, where we start their remuneration, how do you have a career journey in the organisation,” she says.

“We also used data to inform our decision-making.”

The agency undertook two key projects. One looked at pay equity, and involved looking at 80 different roles across the agency and compared them to work-level standards, to ensure the role classifications were correct. The other involved working with an external company to do a pay equity audit to see if there were variations based on age, career, role, gender and other data points.

Armed with the information, it created a plan and selected targets.

“It’s important to understand which things really turn the dial, and what levers you can pull to really reduce the pay gap,” Ms Dolan says.

“You don’t need to reinvent the wheel. .There’ a lot of amazing work and information out there available to you to inform your strategy.”

The key levers for the ACCC were making sure there was a gender split across all classifications of at least 40:40:20, so women and men each making up 40% of position, with the remaining 20% filled by either men or women.

This was particularly important at the most senior levels, she adds.

“There’s no relaxing on the pay gap in my view,” Ms Dolan says.

“You need to have a really consistent effort to make sure that you get it down to zero.”

Celebrating successes

The ACCC’s average total remuneration gender pay gap in 2024-25 was 1%.

ACCC CEO Sarah Proudfoot said reducing the gender pay gap took effort, and a dedicated team.

“It’s not easy,” she says.

“You have to take active, deliberate steps.

“That means being willing to have challenging conversations sometimes around topics that are quite personal.

“We see the gender pay gap as one way we can create a more diverse and inclusive workplace and we want everyone to be able to show up to work being confident they won’t be discriminated against or penalised for their sexuality, their gender, their disability status, their ethnicity.

“I think it comes back to thinking about the community we serve and wanting to make sure that we are actually reflecting that. That we are checking our biases, and that we are making a contribution to society as a whole.”