Missing a target does not automatically mean non-compliance, but employers must show how shortfalls were assessed and addressed. This was emphasised by BEE123 representatives at the 2026 HR Indaba during a session titled EE reporting readiness: Five critical actions every employer should take, now!
Employers are being urged to test their employment equity numbers, evidence and decisions before the Department of Employment and Labour does it for them.
That was the message from Adele Francis, product manager and employment equity advisory specialist at BEE123, and Saul Symanowitz, director of strategic innovation at BEE123. They outlined the steps employers should take now to be reporting-ready.
Adele urged employers to conduct an interim assessment of their employment equity targets to establish where they stand and identify gaps before year-end.
“Leaders need reliable workforce data to identify risks early and make informed decisions about corrective action. They also need to be able to demonstrate that shortfalls have been properly assessed and that decisions are supported by evidence, rather than relying on explanations prepared at reporting time.”
Adele stressed that employers must check whether their affirmative action commitments are translating into practical measures, particularly in recruitment selection and skills development.
“An employment equity plan should be reflected in actual workplace practices, not simply exist as a document for compliance purposes. A formal deviation management process should establish why the target was not achieved, what recruitment or other opportunities arose, what action was taken and what evidence supports the explanation.”
Can you trust the data you are submitting?
Adele, urged employers to introduce formal data verification and sign-off processes before submitting their employment equity reports.
“Employers need a well-maintained evidence file containing relevant workforce records, employment equity plans, and progress assessments. Maintaining these records throughout the reporting cycle, rather than assembling them at the last minute, strengthens governance and enables employers to explain how they arrived at their figures and why particular decisions were made.”
Saul described BEE123 as a tool designed to help employers manage employment equity reporting and track progress against their targets.
“The system serves as a central document repository and a scoreboard of sorts, allowing employers to input their employment equity plans and monitor their performance. It automates calculations and captures both numerical and qualitative information, giving employers a clearer picture of where they stand, how they are performing against their targets, and where gaps may need to be addressed.”
According to Saul the system shows whether an employer is on track, or whether particular demographic groups are underrepresented or overrepresented. It tracks vacancies and helps employers identify which groups to prioritise when filling positions, in line with their plans and applicable requirements.
“By tracking appointments, promotions and terminations, it records demographic trends across race and gender over time. It also logs deviations from targets, along with the reasons given, which can be assessed against the seven permitted grounds for deviation in the department’s framework. Dispute resolutions and their outcomes are recorded too.”
Saul recommended that employers start by establishing their current workforce profile, followed by identifying and prioritising the gaps against targets. He emphasised the importance of documenting deviations and corrective action as they arise, rather than scrambling to compile evidence at reporting time. He advises employers to validate their data, obtain formal sign-off and maintain clear records to ensure every figure and decision can be substantiated.
