A/HRC/62/55/Add.1 (m) The work of dedicated equal treatment and anti-discrimination offices in Styria and Salzburg to address racial discrimination through monitoring, intervention in individual cases and awareness-raising campaigns; (n) The adoption by the City of Graz of the 10‑point Action Plan against Racism and Discrimination; (o) Measures taken by the City of Salzburg to address racism and hate speech, including the adoption of a zero-tolerance approach to hate speech, ensuring accountability for public graffiti depicting Nazi symbols, and workshops on addressing hate speech. IV. Key issues relating to the Special Rapporteur’s mandate A. 1. Cross-cutting considerations Legal and policy framework 10. The Special Rapporteur commends Austria for having legal provisions in place to uphold equality and non-discrimination. Despite welcoming such provisions, she repeatedly received information about protection gaps within the legal framework. This indicated that the legal landscape is highly complex, with non-discrimination provisions being included within laws at both the federal and the Länder levels. In addition, Länder-level laws are not uniform in their protection against discrimination. This fragmented patchwork of legal provisions weakens legal certainty and equal protection before the law. Moreover, there are significant gaps in equality and non-discrimination provisions. There is a lack of full protection against discrimination on the basis of age, LGBTI status and religion, outside of the employment context. Such gaps undermine equality and non-discrimination efforts and limit the effective implementation of an intersectional approach. 11. The equality and non-discrimination institutional frameworks include several bodies at the federal level, including the Equal Treatment Commission and the Ombud for Equal Treatment, alongside institutions at the Länder level. The Special Rapporteur recognizes the important work of all these bodies and welcomed the information about efforts to ensure effective cooperation and coordination. However, such a complex system inevitably leads to fragmentation and to confusion among those seeking assistance and remedy for racial discrimination. Moreover, in an environment of austerity, overlap and duplication risks inefficiency and diverting resources from important preventive work. A process of consolidating and strengthening the mandates of the different equality bodies would be beneficial. Such reform could streamline the process for those seeking assistance and strengthen the overall efficiency and effectiveness of equality and non-discrimination work. 12. The Special Rapporteur welcomes the development of national strategies to address the discrimination, hatred and exclusion experienced by specific groups. This includes the National Strategy for the Inclusion of Roma and the National Strategy against Antisemitism 2.0. Nevertheless, she is concerned about the lack of similar policies to promote the rights of those from other marginalized racial and ethnic groups, including Africans and people of African descent and those affected by Islamophobia. Ensuring that dedicated policies are in place for all groups subjected to racism is important. Moreover, the development and publication of an overarching national action plan on all forms of racism is vital. A national action plan could serve to highlight the needs of all those subjected to racism and offer a shared definition of racism and racial discrimination, including structural forms. It could also be an opportunity to develop an intersectional approach, bearing in mind that identities can overlap. The Special Rapporteur recognizes that there have been public debates about the development of a national action plan but urges Austria to take more timely action. 2. Defining and acknowledging racism 13. The Special Rapporteur frequently noted difficulties with defining race and racism within the Austrian legal and policy framework. She acknowledges the information that she received about difficulties with using the German word for “race”, given its historical connotations. She noted that ethnicity is an acceptable term within the Austrian context. 4