Unveiling new Employment Equity targets
South African universities have until 1 September this year to implement new plans to meet updated Employment Equity (EE) regulations and targets. According to the Department of Employment and Labour (DoEL), this deadline is non-negotiable.
Ms Lucina Reddy, Chairperson of the Employment Equity Managers’ Forum (EEMF) and Employment Equity Specialist at the Cape Peninsula University of Technology (CPUT), was addressing this year’s first sitting of Universities South Africa’s Transformation Managers’ Forum (TMF), of which the EEMF is a subgroup.
Her presentation highlighted differences in representation at the 26 public universities, particularly of black females and persons with disabilities, as institutions group employees slightly differently concerning the EEA9 – the guiding document for occupational levels.
The consultation process regarding the revised Employment Equity Amendment Act (EEAA) and the introduction of sectoral targets started with DoEL in 2018. During early 2022, universities submitted a proposal to DoEL, which was accepted and released in 2022 and again in 2024 for public consultation.
As recently as February 2025, the department invited all institutions from the public and private sectors, in basic and higher education, to a sector meeting where revised targets were presented.
At the March meeting of the TMF, Reddy demonstrated the state of the educational sector and the proposed revised targets, emphasising that DoEL is setting targets for four occupational levels – top management, senior management, professional qualified and skilled.
She explained: “Most institutions are within the proposed representation target for the total at top management, and for black females in top management, we have a similar profile. In terms of senior management, again most institutions are in line with the average or the proposed target. However, there is a significant difference concerning black females in senior management. We also don’t meet targets in the professionally qualified category. This is the group we have to focus on in higher education. The skilled sector is doing well in terms of representation.”
She said the proposed target for persons with disabilities, initially 0.9% in 2022, has been revised to 3% for 2025 — up by 1% from last year.
Reddy said that the Employment Equity Managers (EEMs) immediately compiled a collated response and sent it to DoEL. This included some of the challenges faced in pursuit of the proposed targets.
The EEMF recommendations to the DoEL and the response received:
- Explore the possibility of establishing disaggregated data or sector-specific targets for the higher education sector, given its distinct nature and profile compared to the basic education sector. However, the DoEL is not willing to divide the education sector into various sub-sectors as it believes the proposed sector targets are reasonable.
- Provide clarity as to whether the International Labour Organization (ILO) convention related to the LGBTQIA+ community will be incorporated into the new reporting template. The department does not believe it is contravening ILO conventions. So, no amendments will be made. While this should not prevent Higher Education Institutions (HEIs) from incorporating these measures into their operations, institutions will be required to continue reporting as they currently are.
- Establish reporting guidelines regarding employees or applicants who choose not to disclose their race or gender. The DoEL asked how the EEA1 form is used in the declaration of employees. Institutions responded that this is the process they follow and will continue to do so.
- Consider universities’ mandates around internationalisation – which could impact university rankings, funding requirements and accreditation. This is standard procedure for institutions ; they need to address the matter accordingly.
- The DHET should prioritise strengthening the pipeline of black postgraduate students by offering funding, mentorship programmes and clear career pathways into academia and senior management. Institutions were advised to address the matter directly with DHET as there is a direct reporting line to them. Institutions clarified that this request would be in addition to their ongoing discussions with the DHET.
- The current proposed sector target for persons with disabilities is set at 3%. However, education institutions currently represent only 1.1% combined. Consideration should be given to maintaining the initial proposed target of 2% HEIs need to produce employable graduates – including those with disabilities. The sector is best positioned to implement strategies that effectively engage individuals in these categories.
“In essence,” she said, “there were no shifts or movements on any of the recommendations that the Employment Equity Managers’ Forum (EEMF) put to DoEL.”
Reddy explained that DoEL was expected to gazette the new Employment Equity Act (EEA) Amendment regulations, including sectoral targets and reporting requirements by the end of March 2025.
Roadshows would be conducted on the implementation for the EEA Amendments to develop organisations’ capacity. Failure to comply with the EEA targets would render the institutions ineligible for compliance certificates required for participation in government projects in South Africa.
EE profiles need to be reviewed
Reddy urged institutions to review their EE profiles urgently, concerning the EEA’s Employment Equity Plans (EAPs) and the revised proposed sectoral targets. This includes completing the new EEA12 form. Furthermore, institutions must analyse their barriers to the implementation of EE, considering the more ambitious targets and the affirmative action measures that must be incorporated into the new EE plan.
She said the EEMF would convene to discuss the initiatives required of the sector for collective implementation. Additional support would be requested from the DHET, other funding stakeholders and the USAf Board.
In the ensuing discussion, Ms Ntsikie Loteni, Director: Transformation at the University of Pretoria, said institutions had to be “intentional” when it came to meeting some of the targets. “Universities are in control, particularly when it comes to targets for people with disabilities. Asking DoEL to lower the target might be seen as an insult to the people concerned.”
Ms Noko Mailula, Deputy Director: Social Inclusion and Equity at the DHigher ET, agreed. “I think for large institutions to be at 1.1% of persons with disabilities at this time is unacceptable; it doesn’t show an intention to transform the sector. In terms of what is happening right now in the code, and internationally, we are supposed to be above 3.5% because we should be at 7% employment of persons with disabilities by 2030. The same goes for our service providers; we should be empowering businesses owned by persons with disabilities.”
Reddy agreed that both the EEMF and TMF had to continue to drive the disability agenda. The goal is to make the university workspace more inclusive by placing disability at the centre of universities’ planning.
She praised the sector for the work it has done to date.
“When we looked at the employment equity and transformation landscape in 2022, we realised that not much had shifted. However, when we repeated the exercise in 2024, we found tremendous improvement, including building a solid foundation in the sector. We must now stretch the targets and support one another in this process.”
Janine Greenleaf Walker is a contract writer for Universities South Africa.
