Preparing for mandatory gender pay gap action plans in the UK

Gender pay gap reporting has been a feature of the employment law landscape for almost a decade. In that time, we have seen the pay gap shrink by about 25%, and it currently stands at 6.9%, although progress to closing the gap has slowed down recently. A TUC report earlier this year predicted that we cannot expect pay parity until 2056 and that women effectively work for free for a month and a half each year. 

What is changing under the Employment Rights Act 2025?

As part of the government’s plan to Make Work Pay, the Employment Rights Act 2025 (ERA) introduces the requirement for larger employers to publish gender equality action plans. These aim to create meaningful, long-lasting cultural change to support gender equality. 

Who does this apply to?

Employers who have to publish a gender pay gap report, those with 250 or more employees, will also have to publish an action plan to address any gap and set out how they are supporting those experiencing menopause. 

Whilst publication of plans is only required of larger employers, the government guidance encourages businesses with fewer than 250 employees to also look at the actions they could take.

Key dates and deadlines for compliance

You are not required to produce an action plan for 2026-2027; this will be voluntary. Your first mandatory report will not be due until 2028, and there will be a soft phase in process before then:

April 2026

Once the current gender pay gap reporting deadline has passed, the section of that website where you can publish your equality action plans will go live. You can then post your voluntary report covering 2026-2027 at any time before the gender pay gap report deadline in 2027.

April 2027

Reporting becomes mandatory and will cover the year 2027-2028.

31 March (public authorities) / 5 April 2028

Your first mandatory action plan covering the year 2027-2028 must be submitted along with your gender pay gap report.

What must be included in the gender equality action plan?

We know that employers will need to select at least one action to address their gender pay gap and at least one action to support employees experiencing menopause. 

Although not a requirement, employers can choose to expand menopause support to encompass those whose menstrual health might impact their wellbeing in the workplace, such as those with endometriosis, fibroids or polycystic ovary syndrome. You are also encouraged to consider the overlapping impact of sex on other characteristics such as ethnicity, disability and socioeconomic background. 

How to identify and address your gender pay gap

Before you can assess which action or actions might be appropriate for your organisation you will need to identify the cause of your gender pay gap. Further guidance is expected in April setting out how you should analyse data and monitor improvements. That will include new guidance on analysing data and monitoring improvements.

In the meantime, the government has given us some evidence-backed actions that employers can include in their plans. These include stating salary ranges in job adverts, advertising flexible working arrangements, using fair, structured interview questions, and increasing pay transparency. It also addresses access to training and promotions. 

The Government intends to keep these recommendations under review, update them and look for feedback from employers too. So, keep an eye out for further developments.

How employers can prepare now

• Senior leadership will need to sign off on your action plan so their early buy-in will be essential in this process. Your managers will be key in implementing the actions so consider what training you will need to roll out early on.
• Audit your current situation. This will be required as part of the action planning process as understanding your organisation is essential to determining the right steps in your plan. By looking at your current situation, particularly where your pay gap has been closing, you may find that you are already taking appropriate actions and can demonstrate their effectiveness. It will also help you to be ready to select the actions you might wish to take. 
• Consider how you might engage employees in understanding whether what you are doing or proposing will be impactful for them.

How can we support your action planning?

We provide a full Gender Pay Gap and Equality Action Plan support package which includes:

1. Liaising directly with payroll providers to request the relevant information;
2. Resolving queries and clarification relating to any anomalies or incomplete data to ensure the resulting report is accurate and fully compliant;
3. Preparation of the gender pay gap report in accordance with the regulations with an accompanying explanatory document;
4. An optional narrative and (if applicable) comparison with the previous year’s data.
5. Support and assistance with the development of an equality action plan;

We can also support more broadly with DE&I strategy, coaching, training and mentoring, if required.​​​​​