The management of commitments by higher education institutions to equality, diversity and inclusion both for employees and students presents significant challenges. The implementation of measures to comply with legislative equality requirements, the indicators of commitment to formal equality, do not deliver anything like equality of outcome. This creates the challenge as to how universities may articulate and act on commitments which go beyond formal equality and which may be expected to build a culture of equality, diversity and inclusion. This article addresses the incorporation of equality values and objectives in institutional strategy and the governance arrangements to define, develop and implement measures to address the objectives. Analysing contrasting and coordinated modes of governing I note that a reflexive approach tends to shift regulatory emphasis from control to learning as the basis for effective action. I conclude that it is appropriate and possible that higher education institutions should, to a significant extent, be able to think of themselves as governing EDI matters as much through reflexive learning as through the aspiration to control.