Annual Operating Plan (AOP) 2026-2027

SEPA Annual Operating Plan (AOP) 2026–2027.

This EqHRIA applies solely to the Annual Operating Plan, which sets out SEPA’s key activities, targets, and milestones for the 2026–2027 financial year.

06/03/2026

Darren McKay, Performance Manager and Susan Deakin, Senior Business Consultant

Kirsty-Louise Campbell, Chief Officer: Governance, Performance, and Engagement

Yes. The relevant assessments considered include:

• Data Protection Impact Assessment (DPIA)
• Islands Communities Impact Assessment (ICIA) – SEPA has confirmed under S8 that no implications apply
• Any further assessments that may apply to individual workstreams within the AOP

SEPA is required to publish an annual operating plan for each separate year of the Corporate Plan. This should include key targets and milestones for the year immediately ahead and be linked to budgeting information so that, where possible, resources allocated to achieve specific objectives can be identified.

The primary audience for the annual operating plan is the external stakeholders and wider public as well as SEPA colleagues.

The annual operating plan aims to outline SEPA’s annual programme of work and key deliverables set in the context of our statutory purpose and functions and Corporate Plan priorities:

• Net Zero
• Water Environment
• Climate Resilience
• Resource Efficiency
• Business Environmental Performance
• Our organisation and Transformation

SEPA’s statutory purpose is to protect and improve the environment in ways that, as far as possible, also create health and wellbeing benefits and sustainable economic growth. We do this by regulating activities that may cause environmental harm, managing flood risk, and promoting sustainable use of natural resources, while ensuring this protection is delivered fairly and recognising that environmental risks can disproportionately affect vulnerable and disadvantaged communities.

Key features of the annual operating plan include opportunity/challenge we are addressing, key areas of focus, expected impact as well as milestones and performance measures.

Equality and Human Rights relevance:

• The annual operating plan applies to all SEPA staff and all external stakeholders accessing SEPA services.
• It takes account of SEPA’s public sector equality duties by ensuring no accessibility barriers are created for protected groups.
• It ensures SEPA’s actions support the rights to health, environmental protection, access to information, and non‑discrimination.
• The annual operating plan will include a section on Equality, Diversity and Inclusion which outlines SEPA’s 2026-2030 Equality Outcomes and signposts to further equality information on SEPA’s website.
• As a high‑level annual operational plan, detailed impacts will come from individual programmes or workstreams, each of which will complete their own EqHRIAs where relevant.

SEPA’s Equality Outcomes 2022–2026

• Outcome 1 – We have increased the number of people from currently underrepresented groups in our applicants, our staff and those who progress within the organisation.
• Outcome 2 – People with lived experience of inequality, related to a protected characteristic or socioeconomic status, access and use SEPA’s services without barriers.
• Outcome 3 – Staff with lived experience of inequality and barriers, and with a wide variety of needs, feel listened to and respected as SEPA meets those needs.
• Outcome 4 – We have decreased our gender pay gap and occupational segregation related to gender, disability, and ethnicity.

The annual operating plan doesn’t directly relate or contribute to SEPA’s Equality Outcomes however the publication of the document relates primarily to Outcome 2.

• Using simple, plain English that can be understood by people with low literacy or for whom English is not a first language.
• Providing access to the document in an alternative format or language.
• Ensuring compatibility for people who use screen-reading and/or screen-magnifying software.
• Exploring a proactive easy read version and a British Sign Language summary version of the plan.

Some areas outlined in SEPA’s annual programme of work and key deliverables can relate to the Outcomes (noted below). The detailed impacts will come from individual programmes or workstreams, completing their own EqHRIAs where relevant:

• Outcome 1: Increasing workforce diversity – supported through commitments such as leadership development, workforce planning and the People Strategy.
• Outcome 2: Barrier‑free access to SEPA services – supported through new customer experience strategy implementation and work to align our processes, systems and communications in response to our customers’ needs and expectations. Through more joined-up, consistent and accessible services – both internally and externally – we will enhance how we interact and engage with customers.
• Outcome 3: Staff feeling listened to and respected – supported through people strategy, colleague survey and commitment to supporting colleagues and creating a positive, safe and welcoming place to work. 

Yes, the annual operating plan defines SEPA’s operational work for the year. This outlines where staff prioritisation, decision‑making, and service delivery across Scotland have been agreed.

Stakeholders, which may include persons with one or more protected characteristic, who may be impacted include:

• SEPA colleagues
• External stakeholders including Scottish Government, public bodies and partner agencies, Scottish businesses, non-government organisation and trade associations
• Communities and the general public.

Engagement undertaken:

• SEPA colleagues were engaged in the content development of the plan through online discussions, topic-based workshops and in writing, via telephone and Microsoft Teams.
• Scottish Government colleagues were engaged via direct discussions and in writing.
• External stakeholders would be engaged depending on the specific work area outlined in the plan. For example, as we prepare to regulate the deposit return scheme, we would plan to engage with obligated businesses and trade bodies to ensure they are satisfied with our regulatory guidance and support. We would also look to target engagement with industry stakeholders on our Environmental Authorisation (Scotland) Regulations.

Additional engagement will take place for operational workstreams or specific projects arising from the Annual Operating Plan and will be documented in individual EqHRIAs as required.

• Previous EqIAs for Corporate Plan / Annual operating plan.
• Findings from internal and external engagement activities.
• Internal workforce demographic data.
• Employee engagement.
• Equality outcomes development workshop sessions.

Amongst your group of stakeholders are there any people who belong to the protected characteristic groups listed below who may be impacted, either positively or negatively, or do you believe there is a neutral impact?

Consider the three needs of the general duty for each protected characteristic in turn.

Table 1 - Public Sector Equality Duty - Screening tool

Where operational workstreams could create differential impacts, separate Equality and Human Rights Impact Assessments will be completed to understand, mitigate, and monitor those impacts.

No

As a high‑level planning and reporting document, the Annual Operating Plan does not introduce measures that directly affect or restrict individuals’ Convention rights or freedoms.

Table 2 - Human rights consideration

• Eliminate unlawful conduct
• Advance equality of opportunity
• Foster good relations

Developing and publishing the annual operating plan has a potential impact of discrimination for disabled people, older people and people for diverse ethnic communities due to lack of access, lack of accessibility / overly technical information or language barriers.

The annual operating plan should be available to all colleagues, external stakeholders and members of the public engaging with SEPA, which may include persons with protected characteristics. 

The production and publication of the Annual Operating Plan is endorsed by the SEPA Board and Corporate Leadership Team. We are committed to ensuring that all people have an equal opportunity to access our Annual Operating Plan and we will make reasonable adjustments to meet specific needs of customers wherever possible including different formats and translations.

Specific engagement will take place for operational workstreams or specific projects arising from the annual operating plan and will be documented in individual EqHRIAs as required.

There is potential positive impact on fostering good relations and advancing equality of opportunity. The Annual Operating Plan will:

• Be accessible in HTML digital formats, ensuring compatibility for people who use screen-reading and/or screen-magnifying software.
• Use simple, plain English that can be understood by people with low literacy or for whom English is not a first language.
• Offer an option to request access to the document in an alternative format or language.

Yes, the following will impact on persons with protected characteristics and with lived experience of protected status inequality:

• Failure to offer a non-digital option alternative format for persons contacting SEPA.
• Failure to meet accessibility standards in our digital publication.
• Failure to offer and provide access to translation services for persons where English is not their first language.

We will look to provide a proactive easy read version of the plan. Easy read is designed for people with learning or intellectual disabilities. It can also help others, such as neurodivergent people, people with hearing or visual impairments, people whose first language is not English, parents or carers of disabled people and people who have problems with reading

We will look to provide a proactive British Sign Language summary version of the plan for persons who are Deaf/deaf to create an inclusive culture and pre-empt requests. Based on official statistics from the Scotland Census 2011, we believe there are 12,556 British Sign Language users, of which 7,200 of these are Deaf.

Where any risk of negative impacts on persons with lived experience of protected status inequality are identified or brought to our attention, performance staff will liaise with the Equality and Human Rights Lead, to consider and implement any necessary actions to eliminate or limit such risk.

Sources

• Previous EqIAs for Corporate Plan / Annual Operating Plan
• Findings from internal and external engagement activities
• Internal workforce demographic data
• Employee engagement
• Equality outcomes development workshop sessions
• Scottish Government Easy Read – Service Manual
• British Deaf Association – Help & Resources
• Engagement with colleagues who are members of SEPA Lived Experience Groups
• Reference to the Offline and Overlooked campaign on the Age UK website
• Reference to a Audit Scotland publication: Tackling digital exclusion

Language barriers

When considering the potential for language barriers in questions 2.2 and 3.5, a review of Scotland’s Census found that:

• Polish was the most commonly spoken language in Scotland after English, Scots and Gaelic. 54,000 people - about 1.1% of Scotland's population - said they spoke Polish at home.
• Languages other than English, Scots and Gaelic were most common in the big cities. About 12% of people in Aberdeen, Edinburgh and Glasgow said they spoke other languages around the home.
• The most commonly spoken languages at home other than English and Scots were:
• • Polish (54,186 people)
  • Chinese languages (27,903 people)
  • Urdu (23,394 people)
  • Punjabi languages (23,238 people)
  • French (14,623 people)

Digital inclusion

With respect to digital exclusion, the Equality Evidence Finder provided the following information:

• One in six Scottish adults lack the digital skills needed for everyday life.
• Digital exclusion impacts people who do not or cannot fully use digital technology. It affects people in different ways. Those who:
  • Are unable to afford an appropriate device or internet connection
  • Do not have the skills and confidence to use digital technology
  • Have a fear or mistrust of using online services or lack the motivation to do it
  • Have difficulty in accessing digital services and devices or an internet connection
  • Are unable to keep up with the pace of change of digital technology.
• Age: Older people are less likely to use the internet at home. There are lower rates of internet use among older adults than among younger adults. In 2019, almost all (99%) adults aged 16-24 reported using the internet compared to 43% of those aged 75+. Source: Scottish Household Survey 2019 (last updated: September 2020).
• Disability: Disabled adults are less likely to use the internet. In 2019, 64% of older adults (aged 60-74) with a disability reported using the internet. This was lower than reported internet usage amongst older adults who are non-disabled (85%). This disparity in internet usage decreases in younger age groups, with a 7 percentage point difference in usage between 25-34 year olds who are disabled and those who are nondisabled.

There are four options. Select the one that is appropriate to your findings and provide any supporting information you have for that decision.

Option 3: Continue the policy / practice

This means that you adopt or continue with the policy, despite the potential for adverse impact. You should clearly set out the justifications for doing this, and how you believe that decision is compatible with SEPA's obligations under:

• The Public Sector Equality Duty; and
• The Human Rights Act.

Where you believe indirect discrimination is not unlawful because it is “objectively justified” please record what the objective justification is for continuing the policy / practice, and how you reached this decision.

This option is selected following the considerations in the Full Assessment in section 3.

Whilst SEPA’s Annual Operating Plan does not present any barriers to the advancement of equality or to the fostering of good relations with persons with lived experience of protected status inequality, the current focus on digital services may present barriers.

Persons with lived experience of protected status inequality may experience difficulties when trying to access SEPA’s Annual Operating Plan for reasons such as age, race (i.e. where English is not first language), visual impairment or other disability.

“No major change” is not seen as a viable option, nor would “adjustment” of the Annual Operating Plan in its own right provide a solution.

Removing or discontinuing the Annual Operating Plan would compromise SEPA’s ability to meet its strategic and statutory responsibilities, creating a significant governance gap and exposing the organisation to major operational and reputational risk.

The most appropriate option therefore is Option 3: “Continuing” the Annual Operating Plan with improvements to its accessibility as outlined in sections 3.4 and 3.5, and subject to continuous monitoring and improvement.

17/04/2027

17/04/2026

Yes