Employers can publish their equality action plans voluntarily from April 2026 before it becomes compulsory from 2027. One of the new requirements under the Employment Rights Act 2025, action plans aim to encourage employers to take effective action to improve gender equality at work, focussing on the gender pay gap and supporting employees experiencing menopause symptoms.

The key change is that employers will no longer only publish gender pay gap data – they will also need to explain what actions they are taking to reduce the gap. The government has now published basic guidance for employers on what an action plan should cover and lists of actions that employers could take to reduce the gender pay gap and support employees experiencing menopause. The government will publish additional guidance in April 2026.

How UK gender pay gap reporting currently works

To help reduce the ongoing pay gap between men and women, all employers with 250 or more employees must report their gender pay gap on the “snapshot” date of 5 April for private sector employers or 31 March for public sector. They must report by 4 April (or 30 March) the following year and upload their report to a government website (as well as their own website if they wish).

Employers must publish six figures: their mean and median hourly pay gap; their mean and median bonus pay gap; the proportions of men and women receiving bonuses; and the number of men and women in each of four pay quartiles. We’ve written FAQs covering all aspects of gender pay gap reporting.

This regime encourages transparency but, in itself, does not force employers to take action to address inequalities. By shining a spotlight on certain employers, the scheme has worked indirectly to shame them into taking remedial action on their own initiative. This is about to change, and employers will be required to show what action they are taking to reduce the pay gap not merely report on it.

Current legal obligations relating to menopause at work

Although ‘menopause’ strictly means when a woman’s periods have stopped permanently and is diagnosed when she has not had a period for 12 months, the government includes perimenopause (when you have symptoms but your periods have not yet stopped) and post-menopause within the term. It is typically experienced by women aged between 45 and 55, although it could be earlier or later.

Employers currently have no specific obligations to assist women going through the menopause unless a failure to do so would amount to sex, age or disability discrimination or (in rare cases) a breach of the implied term of trust and confidence or of health and safety obligations. This too is about to change.

New equality action plan requirements for employers

Employers will have to choose at least one action to address their gender pay gap and one action that supports employees experiencing menopause. Although they are encouraged to be more ambitious and choose a greater number.

Employers will be expected to track the progress of their chosen actions.

Employers may expand menopause-related actions to benefit employees experiencing other health conditions related to menstrual health such as endometriosis, fibroids and polycystic ovary syndrome but this will not be a requirement of the plans.

What is an equality action plan?

An equality action plan is a document published alongside an employer’s gender pay gap report explaining the practical steps the employer will take to reduce its gender pay gap and support employees experiencing menopause. This plan will be uploaded on the same gender pay gap portal that employers are used to using already.

How can employers reduce their gender pay gap?

Employers developing an equality action plan should begin by analysing the underlying causes of their gender pay gap. This will usually involve identifying over/underrepresentation of men and women in different functions and levels of seniority within their business. A deep dive review of the data may uncover some patterns and provide useful insights into the reasons why there is a difference in gender representation. For example:

• reviewing the proportion of men and women at each stage of the recruitment process to identify any potential drop off;
• analysing promotion and recruitment data to identify barriers to progression;
• looking at turnover rates for men and women in different areas of the workforce;
• reviewing starting salaries for men and women (where these are negotiable);
• improving transparency around progression, pay setting and pay structures;
• looking at maternity returners and identifying whether further return-to-work support might be needed;
• improving menopause workplace support policies.

As mentioned above, the government has published a list of actions and employers will have to choose at least one.

We recommend the BIT evidence on “what works” for reducing gender pay gaps. In our experience of advising employers on gender pay gap reporting for almost a decade, we’ve seen those employers that embrace the BIT’s evidence-backed measures achieve big improvements to their gaps. The government’s list of actions largely replicates the BIT’s list.

What should employers do now to prepare for equality action plans?

Check if you will be subject to the new obligations. Organisations approaching the 250 employee threshold, should start preparing so that you’re ready when you meet that point. Organisations not subject to mandatory reporting, should consider doing so voluntarily; there are around 1,000 employers who voluntarily report their gender pay gaps each year. Reporting without an obligation sends a powerful message about gender diversity to staff, job applicants, and external stakeholders

Audit and document what actions you are already taking to support menopausal employees and address your gender pay gap. You may already be taking effective action. Possibly you need to start tracking the impact of what you are doing, or maybe you are doing that too. Knowing what you have in place already and how effective it is will help you decide whether further action or monitoring is needed and what it should be. It will also feed into the commentary you provide on your report and actions. 

Start gathering data. The new guidance advises employers to consider the overlapping impact of sex and other characteristics such as ethnicity, any disabilities and socioeconomic background. Your actions to support women might affect different groups differently. If you don’t already have data on the demographics of your workforce, start gathering it now, so you know how many employees are likely to be experiencing the menopause and what other characteristics they have that might affect meaningful action.

Start considering who in your organisation will need to be involved in formulating, agreeing, implementing and tracking your action plan and how you should start to engage with them. The guidance suggests starting to get buy-in from senior business leaders, who will have to sign off on chosen actions in your plan and managers who will have to implement them. Do you need a project team? Who might need some initial training to understand the upcoming legal obligation? What data will you collect for each measure to be able to analyse its effectiveness?

Consider which other stakeholders you may want to get involved in developing your plan, such as unions and relevant employee networks.

If you already have a menopause policy, consider surveying your workforce’s awareness of it and seek feedback on it. When the more detailed government guidance comes out, you should review the policy in light of it. If you don’t already have a policy, start researching and thinking about what it would include.