Government publishes guidance on gender equality action plans

Background

The government has published guidance for employers on creating gender equality action plans following reforms introduced by the Employment Rights Act 2025.

Under the Act, the Equality Act 2010 will be amended to require employers with 250 or more employees to develop and publish equality action plans setting out steps they are taking to improve workplace gender equality. In particular, the plans must address reducing the organisation’s gender pay gap and supporting employees experiencing menopause.

The requirement will operate on a voluntary basis from April 2026 and is expected to become mandatory from spring 2027 once the relevant regulations are introduced. Action plans will be published through the existing gender pay gap reporting portal alongside gender pay gap data.

Guidance for employers

The guidance explains that large employers will need to commit to at least one action aimed at narrowing their gender pay gap and one action supporting employees experiencing menopause.

To support this, the government has produced lists of suggested actions across areas such as recruitment practices, career development, transparency around pay and promotion, and menopause support. Examples include using inclusive language in job descriptions, adopting structured interview processes, offering mentoring programmes, and providing workplace adjustments or occupational health support for employees experiencing menopause.

Employers are encouraged to analyse workforce data when choosing actions and to seek input from employees, unions, employee networks and HR teams when developing their plans. Senior leaders should approve the final actions and ensure appropriate resources are available for implementation.

Learning points for employers

Employers may wish to start considering how equality action plans could sit alongside their existing gender pay gap reporting processes. Although the requirement will initially be voluntary, it is expected to become mandatory from 2027. The guidance also highlights a range of practical measures that may support wider equality and inclusion objectives, particularly in relation to recruitment practices and workplace support for menopause.

In respect of enforcement for non-compliance, further detail is awaited. The intention is that employers will not be penalised for failing to implement the specific actions set out in their plans. Instead, the regime is intended to operate in a similar way to gender pay gap reporting, with organisations required to publish their plans each year and account for them publicly. Further detail on how any requirement to publish will be enforced is expected to be set out in forthcoming regulations.

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For more information or advice please contact Matt Verrier or your usual contact within our Employment team.