On 7 April 2026, the UK Government published detailed guidance aimed at employers with 250 or more employees, setting out the steps required to create gender equality action plans under the Employment Rights Act 2025.
Although the preparation of gender equality action plans is currently voluntary, it is expected to become a mandatory requirement from Spring 2027. Employers are therefore being encouraged to familiarise themselves with the framework and begin implementing measures ahead of the legal deadline.
The guidance signals a clear policy shift towards encouraging employers to take meaningful, practical steps to improve workplace gender equality. In particular, action plans are intended to demonstrate how organisations will address their gender pay gap and provide support to employees experiencing menopause.
These measures are designed to move beyond passive reporting and instead promote tangible improvements in retention and career progression for women.
Six new guidance documents have been published alongside an overarching framework, each addressing a specific stage in the action planning process. The six-step approach is as follows:
1. Understanding the issues
Employers are required to analyse workforce data to identify the underlying causes of any gender pay gap. This includes engaging with employees to better understand workplace challenges, including the impact of menopause.
2. Choosing actions
Once key issues have been identified, employers must select appropriate measures to address them. The guidance outlines 18 possible actions, with a requirement to adopt at least two—one targeting the gender pay gap and another focused on supporting employees experiencing menopause.
3. Writing a supporting narrative
Each action must be accompanied by a short explanation of up to 100 words, alongside an overarching narrative of up to 200 words outlining the employer’s broader strategy.
4. Submitting the action plan
Action plans must be submitted via the Government’s gender pay gap reporting service. Employers are required to nominate a “responsible person” to approve the submission, although this requirement does not apply to most public sector bodies.
5. Tracking outcomes
Employers are expected to monitor progress against each chosen action to ensure that intended outcomes are being achieved.
6. Reviewing the plan
From Spring 2027, in-scope employers will be required to review and update their action plans annually.
This new framework represents a significant development in the evolution of gender pay gap reporting. Rather than focusing solely on the publication of pay data, employers will now be expected to clearly communicate the steps they are taking to address inequalities.
While some organisations have already adopted a proactive approach, those that have previously limited their efforts to minimum compliance will need to make more substantial structural changes to their reporting and equality strategies in the coming years.
