Gender Equality Action Plans – what’s in store?

The Employment Rights Act 2025 introduces a new requirement for large employers (250 or more employees) to develop and publish equality action plans. The aim is to develop and publish information on steps being taken to improve gender quality in relation to prescribed matters, namely the gender pay gap and support for employees experiencing menopause.

The requirement to publish equality action plans will be voluntary from April 2026, and is expected to become mandatory, for large employers only, from April 2027 (March 2027 for public sector employers). The intention is for the action plans to be published alongside an organisation’s gender pay gap report.

The Government has published new overview guidance for employers on how to develop an equality action plan, alongside a detailed list of evidence-informed actions to include in an action plan. Additional guidance is expected to be made available in April to cover the steps an employer should take in developing their action plan and how to monitor the impact.

What should action plans include?

The guidance recommends that employers select at least one action to address their gender pay gap and at least one to support employees experiencing menopause. This is a relatively low bar to meet and employers are encouraged to go further where appropriate.

Reducing the gender pay gap: suggested actions include reviewing recruitment practices, improving flexible working options, enhancing pay and promotion transparency, and developing leadership pathways for women.

Supporting employees experiencing menopause: the guidance refers to evidence‑based measures such as workplace adjustments, flexible working, targeted policies, manager training, support groups, occupational health input and menopause risk assessments.

These actions should be tailored to the causes of gender inequality in each organisation. The government stresses the need for practical steps that reflect workforce needs, including the experiences of employees with different backgrounds or health conditions.

Practical steps for compliance

HR teams within large organisations should consider taking the following steps to prepare for compliance with the new requirements, ensuring they are in place by April 2027, when the action plans are due to become compulsory.

• Conduct a review of existing policies. Assess whether current gender equality initiatives, menopause policies, flexible working arrangements and leadership programmes reflect the government’s recommended actions.
• Strengthen recruitment and promotion processes. Review job descriptions, advertising strategies and interview processes to ensure they are inclusive and transparent. Check whether flexible working, parental leave and career development opportunities are clearly communicated.
• Plan for menopause support. Introduce or update menopause policies, provide training for line managers and consider adjustments such as temperature control, uniform adaptations or additional breaks. Obtaining occupational health advice may be helpful here.
• Map actions to measurable outcomes. Define clear objectives for each action, identify how progress will be measured and ensure accountability for delivery. This will be essential once action plans become mandatory from 2027.

The guidance recommends that employers should seek the views of a range of employees when developing their action plans, with input from union and employee representatives.

Whilst only large employers with 250 or more employees will be required to produce mandatory action plans, the guidance is aimed at employers of all sizes. Smaller employers are being encouraged to use the support available to develop their own action plans.

Separate regulations will be introduced before gender equality action plans are made compulsory from 2027, and at present it is not clear what (if any) sanction will be applied to employers who fail to comply with the new requirement. This raises the question of how effective these action plans are likely to be in achieving the government’s desired aims.

Gender pay gap reports

A reminder that the annual deadlines for those organisations required to report on their gender pay gap are fast approaching: 30 March for public sector employers and 4 April for private sector employers. Contact us if you require any advice on reporting your data, and we can also put you in touch with specialist pay gap analysts.