About the EHRC Code of Practice

The Equality and Human Rights Commission (EHRC) published an updated Code of Practice following recent legal developments relating to the Equality Act 2010.

The Code provides guidance to organisations on how the Equality Act 2010 should be applied in practice. It helps organisations understand their responsibilities under equality law and covers issues such as discrimination, harassment, victimisation and the rights of people with protected characteristics.

As a university, it may have implications across a range of our activities, services and policies. Although much of the public discussion has focused on sex and gender, we recognise that the guidance raises wider considerations for different members of our community.

Our approach

The University is undertaking a structured review of the EHRC Code of Practice and associated guidance to understand its implications for our policies, procedures and practices.

Given the complexity and significance of this work, it’s important that we take a careful and coordinated approach, based on the law. We want to ensure that any decisions are made thoughtfully, and with proper consideration of how they may affect different members of our community.

Our review is guided by:

• Our legal obligations under the Equality Act 2010 and other relevant legislation
• Freedom of expression and academic freedom
• The dignity, privacy and wellbeing of our community
• Our safeguarding responsibilities
• Our commitment to fostering an inclusive, respectful and welcoming environment

We recognise that this is an important and sensitive topic for many people and that members of our community may hold a range of perspectives.

Current position

While the review is underway:

• Existing University policies and procedures remain in place.
• No changes have yet been made to University policy as a result of the publication of the Code of Practice.
• Departments and teams should not introduce local guidance, processes or practices in response to the Code without agreement through the University's review process.

This approach gives us the time to understand the guidance fully, consider its impact across our community, and engage with staff and students before decisions are made. It will help ensure that any future changes are clear, consistent and informed by both legal requirements and the experiences of those affected.

EHRC Code of Practice Task & Finish Group

The Equity, Diversity and Inclusion Committee (EDIC) has established a dedicated Task & Finish Group to lead this work.

The group brings together colleagues from across:

• Legal Services
• Human Resources
• Student Support and Safeguarding
• Governance and Compliance
• Sport
• Trade Unions
• Staff and student representatives

The group's role is to review the EHRC Code of Practice, consider its implications for the University, engage with stakeholders and develop recommendations for consideration through the University's governance processes.

What will the review consider?

The review will consider a range of issues, including:

• Legal compliance
• Safeguarding
• Facilities and campus operations
• Student and staff experience
• Freedom of expression and academic freedom
• Existing policies, procedures and guidance
• Emerging practice across the higher education sector

The review will also consider the potential impact on different groups within our community.

Consultation and engagement

We are committed to listening to a range of perspectives as part of this process.

The review will include engagement with:

• Staff
• Students
• Trade unions
• Staff networks
• Relevant agencies and departments

Feedback received will help inform recommendations and future decision-making.

Timeline

The Task & Finish Group will carry out its review during Autumn 2026, reporting through the University's governance processes.

Updates will be shared on these webpages as the review progresses.

Frequently Asked Questions

Why is the University reviewing the EHRC Code of Practice?

The Code contains detailed guidance that may have implications for a range of University policies, practices and services. We want to ensure we fully understand those implications before making any decisions.

Has the University changed any policies because of the Code?

No. Existing University policies and procedures remain in place while the review is underway.

Any future changes will be considered through the University's governance processes.

Why aren't changes being made immediately?

We recognise that many people are looking for clarity about what the EHRC Code of Practice may mean for them. However, these issues are complex and affect different members of our community in different ways.

We believe it is important to take the time to understand the guidance fully, seek appropriate legal advice and engage with staff and students before making decisions. This will help us make informed choices that reflect both our legal responsibilities and our commitment to creating an inclusive and respectful environment for everyone.

Will staff and students be consulted?

Yes. Consultation and engagement form an important part of the review process.

We will provide opportunities for staff, students and representative groups to share feedback and help inform recommendations.

Does the review only relate to sex and gender issues?

No. Although much public discussion has focused on sex and gender, the Code covers a wider range of issues relating to equality law and University operations.

The review will consider all relevant implications for the University.

How is the University balancing different rights and perspectives?

We recognise that members of our community may have different experiences and views about the issues raised by the EHRC Code of Practice.

As part of our review, we want to hear a wide range of perspectives from staff and students so that we can better understand the potential impact of the guidance and make informed decisions that reflect both our legal responsibilities and our commitment to an inclusive and respectful community.

What role does safeguarding play in the review?

Creating an environment where people feel safe, respected and supported is important to the University.

As part of the review, we will consider our responsibilities towards staff, students, visitors and younger people who access our services and facilities, alongside the wider impact of the guidance on our community.

Will single-sex and all-gender facilities be considered?

Yes. The University is already undertaking broader work to review and improve facilities across campus to support privacy, dignity and choice for our diverse community.

As part of its remit, the EHRC Code of Practice Task & Finish Group will consider whether the updated guidance has implications for existing or planned facilities provision. Any recommendations will form part of the Group's report and be considered through the University's governance processes.

What should I do if I have questions or concerns?

Questions, comments and feedback can be sent to diversity@bath.ac.uk.

We understand this topic is important to many members of our community and are committed to providing updates as the review progresses.