that only three of 14 members of both NHRIs were women, although in both cases the SCA’s report did not expressly note that this proportion was insufficient to meet the Paris Principles standards.35 In the case of Oman, notwithstanding the reference to the proportion of female members, the SCA also acknowledged that the institution was ‘advocating for an amendment to [its enabling law] to provide for an increased quota of female representation’ and encouraged the NHRI to continue with this advocacy.36 In its March 2022 review of the NHRI of Austria, the SCA noted that there were no legal requirements to support diversity on the NHRI’s board and that all three members of the NHRI’s board being male, yet despite these concerns the SCA reaccredited the NHRI with A status.37 At first inspection, the above examples indicate some inconsistency across SCA jurisprudence on gender representation in the NHRI decision-making body. However, the different approaches also highlight some challenges with the SCA’s reporting process and why caution is warranted when seeking to discern a clear standard that the SCA applies across all contexts. The SCA is always dealing with a question of thresholds – such as whether an institution is considered an A- or Bstatus – with a range of different issues impacting on whether an NHRI surpasses that particular threshold. Whether a single issue, such as insufficient gender diversity on the NHRI decisionmaking body, will lead to an adverse accreditation outcome is a question of degree and considered among a range of matters of Paris Principles compliance, not all of which are listed in the SCA’s public report. NHRIs with an adverse recommendation on gender diversity in its leadership also face the challenge that the procedures which define the composition of its decision-making body and the appointment of members are outside of the direct control of the NHRI. While the absence of state involvement in the accreditation of NHRIs serves to inhibit political interference and lends the process its peer-review character, it also limits the scope of recommendations available to the SCA, which can only direct its recommendations to NHRIs. Accordingly, the SCA lacks the mandate to expressly direct its recommendations to governments or states. The only response available to NHRIs in such cases is to advocate with their national government or parliament to take action to address the SCA’s recommendations, usually through legislative amendments or policy change. Gender representation and diversity among NHRI staff As referenced in General Observation 1.7 above, an NHRI may also address the requirement of pluralism under the Paris Principles through ‘staff that are representative of the diverse segments of society’.38 It should be emphasised, however, that pluralism through staffing measures is not an option that can displace the requirement for commission-model NHRIs to have a diverse decisionmaking body. The SCA will expect such institutions to ensure pluralism in both contexts. For example, in its 2021 accreditation of the NHRI of Mongolia, the SCA explicitly noted the issue of pluralism in the NHRI’s leadership, staff, and also its advisory bodies.39 Adopted-Report-October-2022-EN.pdf> (‘October 2022 SCA Report’) 23-24 (Indonesia); Global Alliance of National Human Rights Institutions, Subcommittee on Accreditation, Report and Recommendations of the Virtual Session of the Sub-Committee on Accreditation, 18-29 October 2021 < https://www.ohchr.org/sites/default/files/2021-12/SCA-ReportOctober-2021_E.pdf> (‘October 2021 SCA Report’) 34-35 (Sri Lanka). 35 See October 2021 SCA report, ibid 17 (Qatar); May 2024 SCA Report (n 15) 52 (Oman). 36 May 2024 SCA Report, ibid 51 (Oman). 37 Global Alliance of National Human Rights Institutions, Subcommittee on Accreditation, Report and Recommendations of the Virtual Session of the Sub-Committee on Accreditation, 14-25 March 2022 <https://www.ohchr.org/sites/default/files/2022-04/SCA-Report-March-2022_E.pdf> (‘March 2022 SCA Report’) 13-14 (Austria). 38 General Observations (n 16) 20. 39 October 2021 SCA Report (n 34) 13-15 (Mongolia). 8 Gender Equality and the Paris Principles