Institutionalising Intersectionality in the 'Big Three'? The Changing Equality Framework in France, Germany and Britain Costanza Hermanin and Judith Squires This chapter evaluates the ways in which the legal and normative demands of multiple equality strands are being addressed institutionally in the so-called ‗big three countries' of Western Europe. It deploys comparative analyses of current state-level reforms in the different types of institutions designed to implement equality policies in France, Germany and Britain. The chapter documents the ‗policy legacy' in the domain of equality found in each country at the beginning of the twenty-first century, the patterns of legal-political reforms underway, and evaluates the potential of these reforms for ‗institutionalising intersectionality'. On the basis of the transitions documented we argue that while all three countries have introduced significant changes to their anti-discrimination institutional machinery, substantial differences nonetheless exist in the nature and scope of these revisions. Overall, we find little evidence of convergence towards an integrated multiple-inequalities approach. In two out of three countries, we have identified a movement from equality regimes that place particular emphasis on gender equality towards antidiscrimination regimes that integrate multiple strands under common policy and institutional umbrellas, but which nonetheless maintain differing levels of institutionalization between gender and other grounds and which entail very little in the way of intersectional structures. In Britain, on the contrary, we do see a switch from a binary system focused on race and gender towards a more clearly-defined multiple equality framework. Both the Equal Pay Act 1970 and the Sex Discrimination Act 1975 (SDA) fell into an antidiscrimination perspective (Gregory 1999). The SDA made it unlawful to discriminate on the grounds of sex in employment, education, advertising or when providing housing, goods, services or facilities (EOC 2004). Positive discrimination was not lawful under the SDA, though positive action, in the form of allowing discrimination in training, or encouragement to apply for particular work in which members of the relevant sex are under-represented, was. This antidiscrimination approach to gender equality was complemented, much later by the introduction of gender mainstreaming and the creation of a Women's Unit (WU) and a Minister for Women in 1997, allowing the Government to state that: ‗gender mainstreaming will complement gender equality policies to form a twin track strategy.' (Cabinet Office 1998) Whereas the Equal Opportunities Commission (which was a quasi-autonomous state agency) was charged with working to end sex discrimination, the WU (which was a crosscutting unit within Whitehall) was created to ensure a coordinated approach to gender equality across government departments. In contrast to both France and Germany, Britain introduced race equality legislation alongside its sex discrimination legislation, generati...