Digital Licensing - Integrated Authorisation Framework (IAF) Application Service
Section 1 - Scoping
Digital Licensing – Integrated Authorisation Framework (IAF) Application Service and Permissioning Platform.
SEPA’s role as Scotland's principal environmental regulator is to protect and improve the environment by ensuring that activities which could cause harm, such as pollution or resource misuse, are properly controlled.
The Environmental Authorisations (Scotland) Regulations 2018 aim to create a more streamlined and integrated system for environmental authorisations in Scotland. They bring together the processes for authorising, enforcing, and managing activities that may impact the environment, including:
- Water activities.
- Waste management activities.
- Industrial activities.
- Radioactive substances.
This Equality and Human Rights assessment is for the online application service which will allow people who require an environmental Authorisation from SEPA to operate under the incoming Environmental Authorisations (Scotland) Act 2018 to submit the information SEPA needs to assess their application and, where appropriate, issue them with an authorisation.
The service will accept applications for 269 regulated activities. Activities not included in the service are private sewage treatment authorisations, waste carrier authorisations, and radioactive substances authorisations as these all have their own separate online application services.
The permissioning platform is the back-office system which SEPA staff will use to store and access the information submitted by applicants.
03/09/2025
Principal Product Owner
Head of Function (Permitting)
Yes – a Data Protection Impact Assessment for the service has been completed.
Section 2 - Screening
The implementation of the Environmental Authorisations (Scotland) Regulations 2018 (EASR) via SEPA’s Integrated Authorisation Framework (IAF) requires an overhaul of SEPA’s approach to permitting in order to make the process more accessible for as wide an audience as possible.
The Integrated Authorisation Framework Application Service has been designed to allow applicants to digitally submit the information SEPA requires from them during an application determination.
The Permissioning Platform has been designed to gather and collate this information and present it to SEPA staff in a way which allows them to carry out their duties in respect of assessing and issuing authorisations.
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.
This work will deliver on Outcomes 2 and 3 by expanding access to SEPA’s online digital licensing services to under-represented groups and people with lived experience of protected status inequality by:
- Upgrading functionality for people who use screen-reading and/or screen-magnifying software.
- Using simple, plain English that can be understood by people with low literacy rates or for whom English is not a first language.
- Using Digital Scotland Service Standards for the design and customer journey so that people with low digital skills can fully access the services.
- Providing an online service designed with input from SEPA staff which integrates with existing SEPA technologies to provide a simpler and more streamlined way of performing their roles.
Yes, applicants will now be able to submit applications for all SEPA authorisations using a digital system.
The new service will impact on:
- Direct applications to SEPA (a nominated representative, or an obligated individual will be required to provide permit application information).
- SEPA Staff, who will be administering and using the service.
2.6
The Equality Act 2010 places a duty on public bodies to prevent discrimination in all aspects of service provision. It provides a clear and positive legal duty to eliminate discrimination and to ensure equality of opportunity and good relations between different groups.
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
|
Eliminate discrimination, harassment and victimisation and other conduct prohibited under the Equality Act |
Advance equal opportunities between people who have a protected characteristic and those who do not |
Foster good relations between people who have a protected characteristic and those who do not |
|
| Age | Negative | Positive | Positive |
| Disability | Negative | Positive | Positive |
| Gender reassignment | Neutral | Neutral | Neutral |
| Marriage / Civil partnership | Neutral | Neutral | Neutral |
| Pregnancy / Maternity | Neutral | Neutral | Neutral |
| Race | Negative | Positive | Positive |
| Religion / Belief | Neutral | Neutral | Neutral |
| Sex | Neutral | Neutral | Neutral |
| Sexual orientation | Neutral | Neutral | Neutral |
2.7
Will the policy or practice engage or restrict a right or freedom under the Convention?
If you answer 'Yes' for any of them, go to Section 3.
Human Rights human lives a guide for public authorities.
Table 2 - Human Rights consideration
|
Human Rights Act Article |
Yes |
No |
| Article 2: Right to life | x | |
| Article 3: Prohibition of torture | x | |
| Article 4: Prohibition of slavery and forced labour | x | |
| Article 5: Right to liberty and security | x | |
| Article 6: Right to a fair trial | x | |
| Article 7: No punishment without law | x | |
| Article 8: Right to respect for private and family | x | |
| Article 9: Freedom of thought, conscience, and religion | x | |
| Article 10: Freedom of expression | x | |
| Article 11: Freedom of assembly and association | x | |
| Article 12: Right to marry | x | |
| Article 13: Right to an effective remedy | x | |
| Article 14: Prohibition of discrimination | x | |
| Protocol 1, Article 1: Protection of property | x | |
| Protocol 1, Article 2: Right to education | x | |
| Protocol 1, Article 3: Right to free elections | x |
If you answer 'Negative' in Table 1 or 'Yes' in Table 2 for any of the questions, please go to Section 3 Full Assessment.
If you answer 'Positive' or 'Neutral' in Table 1 or 'No' in Table 2 for all of the questions you may not need to carry out a full assessment. You should discuss this decision with the senior leader responsible for the work.
If you are content you have completed Section 2 with no negative equality or human right impact, please complete Section 5.
Section 3 - Full Assessment
- Eliminate unlawful conduct.
- Advance equality of opportunity.
- Foster good relations.
The service provides the ability for anyone who might require a SEPA authorisation to provide the information they need to obtain one as quickly and easily as possible via an online digital platform which has been designed with accessibility in mind.
The service will work in tandem with an entirely revised website containing updated guidance and application forms.
For users who may prefer to not use an online service, the option to submit applications via email or post is available and clearly signposted on the website.
SEPA will also provide a paper-based application service and guidance, which is designed to meet the needs of users who cannot, or choose not to, access the digital service.
Our staff are available to help applicants through this process.
Of the protected characteristic groups mentioned in Table 1, above, primarily those who consider themselves to be in the “Age, Disability and Race” categories.
The service is also relevant to people who may not consider themselves to be in these groups but who feel they may face barriers in accessing SEPA’s application process for other reasons. This may include those who are blind or partially sighted, those who are digitally excluded, neurodivergent, those with physical impairment and those with English as a second language.
Of the protected characteristic groups specified in Table 2, the Integrated Authorisation Framework Application service has the potential to directly impact on Age, Disability and Race.
SEPA staff are available to support applicants throughout this process to remove any barriers to inclusion.
General feedback received during Accessibility testing was positive and highlighted the easy-to-use design and layout of the service pages.
The application service provides a single location by which people can submit applications to SEPA as quickly and easily as possible.
The requirements of the application process are set out clearly, and the service includes links to application and guidance forms which have been revised to be accessible and in plain English in order to remove as many barriers as possible.
We have considered the potential negative outcomes around accessibility, digital exclusion and race and have mitigated against those to the best of our ability at this time. We will continue to monitor these areas when the service is live. The Integrated Authorisation Framework application service includes an opportunity for users to provide feedback to help improve the service going forward.
SEPA follows established digital design standards, so each page in the service has a single question that is written in plain English. The screens are uncluttered and use the minimum possible amount of “jargon” to avoid confusion and distress.
Where jargon is unavoidable i.e. on advice from SEPA Legal or where specific technical processes require to be explained in full, guidance using plain English definitions have been provided within the service linked to from appropriate pages.
Accessibility testing was carried out in June 2025 for the Integrated Authorisation Framework application service.
Feedback received from the session resulted in minor textual changes being made. Issues noted with some screen-reading software was highlighted were resolved and the service has been optimised for all major screen-reading software packages.
Accessibility testing on the service was carried out with people who:
- Are sight impaired.
- Are hearing impaired.
- Identify as neurodivergent.
- Have English as a second language.
- Of low digital literacy.
The service was amended to be more accessible based on feedback from these users. The design and build of the system incorporated feedback and “lessons learned” from the accessibility testing carried out as part of the design and build of the PSTS-NEW application system in 2024 and this approach helped embed accessibility into the Integrated Authorisation Framework application service from the start of the project.
In addition, to mitigate any negative impacts the Integrated Authorisation Framework application service has been developed in line with the Scottish Government’s digital strategy and Digital First assessment standards.
Online forms are simpler with one question per page and only ask for information required by SEPA.
Questions are written in plain English to be as clear and simple as possible.
Display fonts, colours and sizes of text and controls are clear and consistent with the Scottish Government’s design system.
On-line forms have been accessibility tested with users that have visual, hearing, physical and cognitive disabilities. Key findings and recommendations have been addressed.
The feedback was used to improve the service before going into production.
Guidance is in place for the digital service, electronic and off-line paper form applications.
The details for Contact Scotland BSL (British Sign Language) are on the SEPA website, for users who wish to access an interpretation service. They are also available from SEPA staff.
Updated, fully accessible guidance relating to EASR has been provided on the updated SEPA beta website so that staff and applicants can better understand their obligations. This is available in digital and paper-based formats and can be supplemented by telephone or video call.
SEPA’s website provides guidance and services, partner organisations, and ways to progress queries that do not fall under SEPA’s remit.
General feedback received from Accessibility Testing was positive and highlighted the easy-to-use design and layout of the service pages. SEPA will regularly monitor service use and take action to address any issues.
SEPA staff that are supporting and administering the service will use MS teams to provide video conference call support.
The application service uses Oracle Apex as the back-office solution. Oracle products are widely tested and work with a wide range of assistive technologies such as screen readers.
Accessibility (Disability)
- 32% of adults had a long-term limiting mental or physical health condition of disability in 2017. Source: SG Scottish Health Survey 2021. (Disability; Population.)
- Only 46% of disabled people of working age are in work. Source: Disabled people in the labour market in Scotland 2018. (Disability; Labour Market.)
- According to the last SEPA Mainstreaming and Outcomes Report 2023, 2.48% of staff declared a disability. Note: there may be under-reporting of this, so it may not be clear how many colleagues have disabilities or the forms of disabilities.
- 2% of the working age population becomes disabled every year, 78% of disabled people get their impairment aged 16 or older. Source: Department for Work & Pensions (DWP).
- As with the wider Scottish workforce and population, SEPA’s workforce is aging, with the largest age group (45-54) sitting at 39.2% of the workforce. With a higher number of older workers, the more pressing these concerns are.
- Significant sight loss affects around 188,000 people in Scotland. This figure is set to double by 2031 due to an aging population. Source: Sightscotland.org.uk. Using those figures as a basis, this now stands at 230.400 people in 2024.
- With regard to displaying map information, 4.5% of the population, are colour blind. Source: BBC.
- 10% of the population are believed to be dyslexic. Source: Dyslexiascotland.org.uk.
- It is estimated that 1 in 7 people (more than 15% in the UK) are neurodivergent. Source: ACAS (national archive).
Accessibility (Literacy)
- 6.2% of Scotland’s population cannot speak, read, and write English. 1.4% of the population cannot speak English well or very well. Source: 2011 National Census.
- 26.7% of Scotland’s population have occasional challenges due to their lack of literacy skills. Of this percentage, 3.6% face serious challenges in their day-to day lives. Source: Scottish Survey of Adult Literacies 2009.
The service underwent accessibility testing in June 2025 with results provided in an Accessibility Test Report.
Section 4 - Continuous monitoring and improvement
Option 2: Adjust the policy / practice
This involves taking steps to:
- Remove barriers, to better advance equality or to foster good relations.
- To minimise any restriction of Convention rights or freedoms.
It may be possible to remove or change the aspect of the policy that creates any negative or unwanted impact. You should describe additional measures which could be taken to reduce or mitigate any potential negative impact.
The service underwent accessibility testing in June 2025. The Accessibility report identified areas for improvement and changes have been implemented prior to the service going live.
The service includes a form for users to provide feedback upon completion of the application. This will be closely monitored, and issues addressed as they arise. This EqHRIA will be reviewed 6 months after service go live and updated to reflect any changes made to the service to improve accessibility following feedback.
The Equality and Human Rights Impact Assessment is a living document and should be reviewed and updated to ensure you have captured the changes that have been made because of the implementation of your policy or practice. Set a realistic goal for you to check back in with your assessment, to see if things are going the way you expected.
Date for the Equality and Human Rights Impact Assessment review 29/04/2026.
Section 5 - Sign off
22/10/2025
Yes