PART TWO: CONTENT OF COMPREHENSIVE ANTI-DISCRIMINATION LAW noted, this is a fine balance and has led to some interesting case law – in the European Union, for example.524 However, as the Human Rights Committee has indicated, the objective of temporary special measures weighs heavily in this assessment: “as long as such action is needed to correct discrimination in fact, it is a case of legitimate differentiation under the Covenant”.525 4. Positive action under comprehensive anti-discrimination law PART TWO – I Different States have adopted different approaches to positive action under national anti-discrimination legislation. In some countries, detailed guidance is provided on those specific forms of positive action necessary to make progress towards equality, whereas in other countries, this detail is left to other laws and policies. Both of these approaches may work, although it remains important that any specific measures adopted are subject to regular review and that the effectiveness of measures is routinely evaluated. What is most important, to be effective, is that comprehensive anti-discrimination legislation clearly both permits and articulates the requirement for the adoption of positive action. An array of positive action measures have been adopted in States pursuant to their international equality obligations, ranging from the awarding of bursaries or special scholarships to promote equal access and participation in education; to the introduction of quotas, the development of special workplace training programmes and the reservation of places on workplace management courses for members of a discriminated group. What is required in any given circumstance is context specific and must be determined following consultation with a diverse cross section of members of the beneficiary group to which the measure applies.526 Consultation should be carried out in such a way as to ensure the meaningful engagement of all members of affected communities, with particular attention paid to the inclusion of women and girls. KOSOVO: ARTICLE 6 OF THE LAW ON GENDER EQUALITY 1. Public institutions shall take temporary special measures in order to accelerate the realization of actual equality between women and men in areas where inequities exist. 2. Special measures could include: 2.1. quotas to achieve equal representation of women and men; 2.2. support programs to increase participation of less represented sex in decision making and public life; 2.3. economic empowerment and steps to improve the position of women or men in the field of labour improvement of equality in education, health, culture and allocation and/or reallocation of resources; 2.4. preferential treatment, recruitment, hiring and promotion, and other measures in each area where inequalities exist. … 6. [It does] not constitute gender discrimination when public institutions take special measures, including legal provisions, aimed at accelerating the deployment of actual equality between women and men. These measures should cease to exist once they achieve gender equality objectives, for which are created. 524 For a discussion of European Union approaches in the context of employment, see Goran Selanec and Linda Senden, Positive Action Measures to Ensure Full Equality in Practice Between Men and Women, Including on Company Boards (Luxembourg, Publications Office of the European Union, 2013), pp. 9–13. 525 Human Rights Committee, general comment No. 18 (1989), para. 10. 526 See, for instance, Committee on the Rights of Persons with Disabilities, general comment No. 6 (2018), para. 29; and Committee on the Elimination of Racial Discrimination, general recommendation No. 32 (2009), para. 18. 65