addressing this particular concern, it may also create some uncertainty for NHRIs in understanding the SCA’s expectations. NHRI programs on gender-related human rights Neither the Paris Principles nor the General Observations establish any explicit standards for the performance of NHRIs in how they address gender and the rights of women and girls in the exercise of their mandate. Indeed, the Paris Principles standards provide little guidance on how an NHRI should select and prioritise different human rights issues. General Observation 1.2 on the Human rights mandate explains that: [a]n NHRI’s mandate should be interpreted in a broad, liberal and purposive manner to promote a progressive definition of human rights which includes all rights set out in international, regional and domestic instruments, including economic, social and cultural rights.56 The above focus on NHRI ‘interpretation’ of the mandate has been applied by the SCA to require NHRIs to engage across a broad range of human rights issues, even in contexts where there may be an express restriction in the institution’s legal mandate.57 Interrogating how an NHRI interprets its legal mandate will inevitably enliven considerations of how it prioritises its financial resources and the basis on which it elects to develop programs on one thematic issue over another. Despite the lack of prescription in the General Observations on the quality and focus of NHRI thematic programs, these are often issues of focus for the SCA and tend to be raised in more contentious accreditation reviews, typically resulting from allegations of political interference in a third-party submission or a report from the United Nations human rights machinery.58 Documented in SCA reports under the heading ‘Addressing human rights violations’, the SCA will identify where it is concerned that an NHRI has not provided sufficient evidence that it has used its mandate effectively to respond to what the SCA considers to be one or more of the most serious human rights issues in that particular national context. This issue of performance has led to recommendations to downgrade or remove accreditation status from NHRIs in various recent reviews.59 Occasionally, the SCA will also reference specific thematic human rights issues under this heading where it wants to highlight a good practice or where there has been demonstrated improvement in an NHRI’s performance,60 although this is less common. The thematic work of NHRIs on gender or the rights of women and girls does not appear frequently in reports of the SCA. This may be interpreted as an indication that NHRI work on gender-related human rights is not typically seen as a space for political interference with or compromised independence of the NHRI. Conversely, it may represent a lack of focus at the SCA on NHRI performance on gender-related human rights, or a similarly limited engagement on gender performance in third-party submissions or reports from the UN machinery. 56 General Observations (n 16) 7. See, eg, March 2017 SCA Report (n 34) 10 (Lithuania); October 2023 SCA Report (n 56) 10 (Australia). 58 On the capacity of the SCA to receive submissions from third parties, see Global Alliance of National Human Rights Institutions, Rules of Procedure for the GANHRI Subcommittee on Accreditation, 4 March 2019 < https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/GANHRI/ENG_GANHRI_SCA_RulesOfProcedure_a dopted_04.03.2019_vf.pdf> rule 6.7. The SCA has also released two practice notes that address its capacity to receive submissions from third parties and consider other extrinsic materials: Global Alliance of National Human Rights Institutions, Subcommittee on Accreditation, Practice Note 3 – Assessing the Performance of NHRIs, 6 March 2017 < https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/GANHRI/EN_PracticeNote3_AssessingPerformance _adopted_06.03.2017.pdf>; Global Alliance of National Human Rights Institutions, Subcommittee on Accreditation, Practice Note 5 – Sources of information to assess the performance of NHRIs, 18 May 2018 < https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/GANHRI/PracticeNote-5_EN.pdf>. 59 Some recent examples include SCA recommendations to remove accreditation from the NHRIs of Russia and Myanmar: October 2023 SCA Report (n 55) 46-53. 60 See, eg, above examples where an NHRI has interpreted its mandate broadly: (n 57). 57 Gender Equality and the Paris Principles 11