Under the Employment Rights Act 2025, employers with 250 or more employees will need to prepare equality action plans alongside gender pay gap reports. Action plans are voluntary for gender pay gap reports due in April 2027 but will be mandatory for subsequent reporting years. The government has published introductory guidance on the new requirements and expects to produce more detailed guidance shortly.
Employers with 250 or more employees have been reporting their gender pay gaps since 2018. However, until now they have not needed to explain how they are trying to reduce any gaps.
That will change under the Employment Rights Act 2025. In future, equality action plans must accompany gender pay gap reports, outlining measures in place to address gender pay gaps and support employees during menopause. Equality action plans are voluntary for gender pay gap reports due by April 2027 and are expected to be mandatory in subsequent years.
The government recently published initial guidance on the actions employers could adopt and how to track progress against the objectives. Identifying an appropriate action depends on understanding the causes of the gender pay gap and the organisation’s specific needs. Employers should choose at least one action to address the gender pay gap and another to support employees going through the menopause but the guidance encourages employers to go further where possible.
Measures to address gender pay gaps
Depending on a pay gap’s cause, employers may want to focus on different stages of the employment relationship. At the recruitment stage, the government suggests employers could make sure that job descriptions are inclusive to attract a diverse pool of applicants, or publicise flexible working arrangements in job adverts to encourage applications from those with additional needs or responsibilities.
Measures related to staff development and promotion could target appointing more women to senior positions, for example by introducing mentoring, sponsorship and development programmes, or considering all eligible employees for promotion unless they “opt out” of processes. Transparency measures designed to develop and promote family-leave policies could encourage greater take-up of paternity and parental leave, while clearer pay and promotion policies would make it easier for employees to know how to increase their pay or obtain a promotion.
Measures to support employees during the menopause
The guidance highlights various actions to support employees going through the menopause, including training for managers, occupational health advice for employees, workplace risk assessments, and workplace adjustments for employees who need them. Menopause policies typically already provide for workplace adjustments, but the guidance emphasises the importance of dealing with requests quickly and reviewing adjustments regularly to ensure that they are still working for the individual and the organisation.
Next steps
- The government will publish further more detailed guidance about creating action plans in April.
- Employers should decide whether to include voluntary equality action plans in gender pay reports with a 5 April 2026 snapshot date and which equality action measures to adopt.
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