Gender pay gap reporting has been a statutory requirement for large employers since 2017. While the annual publication of these figures is now well established, organisations have engaged with the underlying causes to varying degrees.
This position is now evolving. Under the Employment Rights Act 2025, employers with 250 or more employees will be expected to move beyond the reporting of data and introduce equality action plans. These plans will set out the practical steps being taken to reduce gender pay disparities and provide appropriate support to employees experiencing menopause. The publication of figures alone, without clear context or demonstrable action, will no longer be sufficient.
From April 2026, employers are encouraged to publish action plans on a voluntary basis. This is expected to become a mandatory requirement from April 2027, subject to final regulations. The interim period provides employers with a valuable opportunity to prepare effectively and adopt a considered, strategic approach, rather than treating this as a purely compliance-driven exercise.
What Has Actually Changed
Under the current framework, employers are required to publish six gender pay gap metrics annually: mean and median hourly pay gaps, mean and median bonus gaps, the proportion of men and women receiving bonuses, and the distribution of employees across four pay quartiles.
Crucially, the existing regime does not mandate any form of corrective action. The forthcoming changes mark a clear shift from passive disclosure towards active accountability, requiring employers to articulate the steps they intend to take in response to their data.
The implementation timetable has been deliberately phased. Employers may begin publishing action plans voluntarily from April 2026. The requirement is expected to become mandatory from spring 2027, with the first compulsory publications likely due by April 2028. This phased approach is intended to allow organisations sufficient time to develop considered and credible plans, rather than responding reactively.
What an Equality Action Plan Is Expected to Include
Equality action plans will be published alongside annual gender pay gap reports via the existing government reporting portal.
Based on current government guidance, each plan is expected to include, as a minimum:
- At least one action aimed at reducing the gender pay gap
- At least one action to support employees experiencing menopause, including perimenopause and post-menopause
Employers are strongly encouraged to go beyond these minimum expectations and treat the process as an opportunity to demonstrate a genuine and sustained commitment to workplace equality.
Guidance issued in March 2026 outlines a series of evidence-based actions grouped across five broad categories: recruitment, career development and progression, organisational diversity, transparency, and support for employees experiencing menopause and other health conditions. While employers are not confined to these measures, they provide a useful and credible framework.
Action plans are also expected to be endorsed at senior leadership level, consistent with existing requirements for gender pay gap reporting. Responsibility for these plans should not sit solely within HR; visible leadership accountability will be critical. Employees, investors and clients alike will distinguish between plans that reflect substantive commitment and those that do not.
Why the Menopause Requirement Warrants Particular Attention
Support for menopause has evolved from a peripheral wellbeing issue into a recognised employment law concern, with recent tribunal cases reflecting a growing body of risk in this area.
It is estimated that one in ten women has left employment due to menopause-related symptoms, representing a significant loss of experience and organisational knowledge. While menopause itself is not a protected characteristic under the Equality Act 2010, its effects may fall within the scope of disability where they have a substantial and long-term impact on day-to-day activities. This can give rise to obligations on employers, including the duty to make reasonable adjustments.
The new action plan requirement does not replace these existing legal obligations. Rather, it operates alongside them, increasing transparency and reinforcing accountability. Employers are expected to demonstrate, in practical terms, how they are addressing these issues.
It is also important to recognise that menopause is not experienced uniformly. Employees with additional health conditions or from different backgrounds may require different forms of support. A standardised or generic approach is unlikely to be effective.
The Wider Legislative Direction
The introduction of equality action plans forms part of a broader shift in the approach to workplace equality. The government has also indicated its intention to extend pay gap reporting to cover ethnicity and disability under the proposed Equality (Race and Disability) Bill.
Taken together, these developments signal a move away from a narrow focus on transparency towards a more comprehensive framework of accountability. Organisations that have historically treated gender pay gap reporting as a compliance exercise may find themselves increasingly exposed as expectations continue to evolve.
What Employers Should Do Now
The voluntary period between 2026 and 2027 should be used strategically. Publishing an initial action plan during this time can demonstrate commitment, build stakeholder confidence, and allow organisations to refine their approach ahead of the mandatory requirement.
The starting point should be robust analysis. The six reported metrics provide an overview, but they do not explain the underlying causes. Employers should examine workforce composition, progression pathways, and structural factors such as working patterns and caring responsibilities.
From there, organisations should:
- Identify targeted actions that address the specific drivers of their pay gap
- Establish clear metrics and mechanisms to monitor progress
- Engage employees in the development of the plan to ensure it reflects real workplace experiences
For employers who do not yet have a formal menopause support framework in place, this should be treated as a priority during 2026 rather than deferred until mandatory reporting takes effect.
How The Infinity Group Can Support Your Organisation
Equality action plans represent a significant shift in expectation. Employers are no longer asked simply to report data, but to demonstrate clearly how they intend to address it.
Achieving this requires careful analysis, meaningful employee engagement, and visible commitment at senior leadership level.
At The Infinity Group, we support organisations in understanding their obligations under the Employment Rights Act 2025 and developing practical, credible frameworks to meet them.