Corporate groups

A corporate group, also known as Corporate Structure – is a group of legal entities (subsidiaries) controlled by a parent entity. The Workplace Gender Equality Act 2012 identifies a relevant employer as either a standalone or an entire corporate group.


Employees of a corporate group are employees of their respective employer as well as employees of a parent company. When assessing a corporate groups eligibility the total employee count of the group (of onshore Australia based employees) is used.

  • If your entire group employs 100 or more employees in total – you must register all employing entities with WGEA regardless of their individual entity size
  • Your group will not be required to report when the total employee count across all employing entities falls below 80 for 6 or more months of a reporting period.

Within corporate groups, employing ABNs that themselves employ 100 or more employees are relevant employers in their own right. Gender pay gap information is published for relevant employers. 

Submission groups

A submission group is how data is received by WGEA, one or more ABNs can be part of a submission. A group of legal entities from the same corporate group can choose to submit data in the same report submission to the Agency.

Contact WGEA via email or support request to update your submission groups.

  • Organisations can form a submission group if they are part of the same corporate structure, enrolled in the same program, and have similar workplace policies and strategies as there is one set of questionnaire responses for each submission.

A corporate group can have more than one submission group or report their entire group in one submission if each organisations meets the requirements outlined above

  • You should ideally report more than 80 employees per submission group to ensure that the data is able to be utilised for benchmarking purposes. A submission with a small employee count may not receive an Industry Benchmark Report.

Compliance certificates are issued only when all submission groups within a corporate group have completed the report without recording any issues. 

  • It is the ultimate responsibility of the parent company to ensure all expected submissions are compliant, if a subsidiary submission is non-compliant this will result in non-compliance for the parent company.

Submitting data

You must ensure that all subsidiaries that employ staff are included in your submission(s) to WGEA

  • You do not need to complete separate reports for each ABN, you can combine one or more legal entities into a single ‘submission group’.
  • Each submission is benchmarked on one primary industry activity.


  • Responses must cover all ABNs in the submission accurately
  • Where a conflict exists in post-probation parental leave scheme weeks being offered, employers must list the minimum number of weeks available to all employees covered in the submission.
  • Each questionnaire section contains a free text response that can be used to provide additional context as to how it was answered.

Workforce Management Statistics

  • You must complete one file per employing ABN in your submission group.
  • If a group file is uploaded against one ABN, the data will be taken to be pertaining only to that specific ABN.
  • The section will not be complete until each employing ABN has a file uploaded.

Workplace Profile

  • Employees for each employing ABN must appear in your uploaded file(s).
  • The section will not be complete until each ABN in your submission group has reported employees.