Government publishes detailed framework for gender equality action plans

Background

The government has published detailed guidance for employers with 250 or more employees on how to prepare gender equality action plans under the Employment Rights Act 2025.

From 6 April 2026, large employers can produce action plans on a voluntary basis. The requirement is expected to become mandatory from Spring 2027, subject to further regulations.

The purpose of the action plans is to demonstrate what steps employers are taking to improve gender equality, with a particular focus on reducing gender pay gaps and supporting employees experiencing menopause.

The new guidance builds on earlier high-level materials published in March 2026 and introduces a structured, six-step framework for creating and maintaining an action plan.

What the guidance says

The guidance sets out a clear process for employers to follow.

It begins with a requirement to understand the issues within the organisation. Employers are expected to analyse workforce data, identify the causes of any gender pay gap and engage with employees to understand workplace experiences, including in relation to menopause. There is a strong emphasis on evidence-based decision making and consultation with stakeholders across the organisation.

Once the issues are identified, employers must select actions to address them. At least two actions are required: one focused on the gender pay gap and one on menopause support. Importantly, at least two actions must be new or in progress, rather than already embedded.

Employers must then document their plan, including short supporting narratives explaining each action and a broader statement setting out the organisation’s overall approach to gender equality.

Plans are submitted via the gender pay gap reporting service and must be approved by a designated responsible person.

The guidance also places significant emphasis on monitoring outcomes. Employers are expected to track progress against each action, assess effectiveness and understand how outcomes differ across groups within the workforce.

Finally, action plans must be reviewed and updated regularly. Although full requirements will be set out in legislation, the guidance anticipates annual updates, with more detailed reviews at defined intervals.

Learning points for employers

This guidance provides a clear indication of the level of structure and scrutiny that will apply once action plans become mandatory. Employers within scope should begin preparing now by ensuring they have reliable workforce data and processes in place to analyse it effectively. Early engagement with employees and senior leadership will be critical to identifying meaningful actions rather than relying on generic measures. The emphasis on tracking outcomes means that action plans will need to be more than a compliance exercise, requiring ongoing evaluation and adjustment. While the regime is currently voluntary, employers who act early will be better placed to manage the administrative and cultural demands of the new requirements when they come into force as mandatory reporting requirements next year.

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For more information or advice, please get in touch with Matt Verrier in our Employment team.