New gender pay gap and menopause action plans: what employers need to know

The Employment Rights Act 2025 creates a statutory requirement for employers with 250 or more employees to publish Equality Action Plans, detailing the actions they are taking to close their gender pay gap and provide menopause support. These action plans are voluntary from April 2026, before becoming mandatory from spring 2027.

To help employers with this obligation, the government has published new guidance setting out how employers should prepare gender pay gap and menopause action plans. These plans will sit alongside existing gender pay gap reporting and are designed to drive meaningful, long-term progress on workplace gender equality.

In this article, we provide a reminder of who will be affected by the requirement to publish action plans, outline the government's new guidance, and highlight practical steps for employers. 

The requirement to publish action plans

The new requirements apply to large employers with 250 or more employees. This threshold mirrors existing gender pay gap reporting obligations.

There is no requirement for employers to publish an action plan during the 2026–27 reporting year. However, the government strongly encourages employers to treat that year as a practice run before publication becomes mandatory in spring 2027, subject to secondary legislation.

What has been published?

The Government Equalities Office has released guidance outlining a new framework for employers to publish Equality Action Plans. The plans require employers to:

• choose at least one action aimed at reducing their gender pay gap; and
• choose at least one action to support employees experiencing menopause, including perimenopause and post-menopause.

Employers can also use action plans to highlight work they are already doing to improve workplace gender equality.

The guidance makes clear that the purpose of these plans is to promote practical, evidence‑based steps that advance equality of opportunity between men and women. The government is encouraging employers to go further than the minimum two actions and select additional commitments where possible.

The guidance is complemented by a detailed list of 18 recommended, evidence‑informed actions. Further guidance is also promised in April 2026.

How should employers prepare their action plans?

To prepare an effective action plan, the guidance encourages employers to follow a five-step process:

1. Understand the issues: analyse your gender pay gap data, identify the drivers behind it, and speak to employees to understand any workplace barriers, taking account of how sex may intersect with characteristics such as disability or ethnicity.
2. Select your actions: choose at least one action to reduce your gender pay gap and one to support employees experiencing menopause, supported by a short narrative explaining your choices.
3. Submit your plan: publish your action plan via the existing gender pay gap reporting service alongside your annual reporting.
4. Track progress: monitor outcomes and collect data to assess whether your chosen actions are working. Suggestions for measuring progress are contained in the suggested list of actions.
5. Review annually: update your plan annually as part of the ongoing reporting and review cycle.

More details on this process will be published in April 2026.

Recommended evidence‑informed actions

The government’s list of 18 recommended actions is designed to help employers choose interventions that are practical and backed by evidence. The action documents are helpfully accessible, pragmatic, and well worth reviewing. They fall under five themes:

1. Recruiting staff

Examples include:

• making job descriptions inclusive and appealing to diverse candidates;
• reducing unconscious bias in CV screening; and
• encouraging applications from a range of candidates.

2. Developing and promoting staff

Actions include:

• automatically considering eligible employees for promotion; and
• offering mentoring and sponsorship.

3. Building diversity into your organisation

Such as:

• setting and monitoring targets to improve gender representation.

4. Increasing transparency

Actions include:

• increasing transparency on pay, promotion and rewards; and
• enhancing and promoting flexible working and leave policies.

5. Supporting women with health conditions and menopause

Examples include:

• training managers to support employees;
• providing access to occupational health advice;
• offering support groups or workplace adjustments; and
• conducting menopause risk assessments.

Each action is accompanied by guidance on its purpose, benefits and evidence, along with suggestions for implementation and tracking progress. Employers are encouraged to select actions that reflect their organisation’s data, workforce demographics and specific needs.

Practical takeaways for employers

• Start early: use the 2026–27 voluntary window to trial your first action plan. Voluntary publication signals a commitment to equality, builds confidence with employees, investors and customers, and gives time to refine your approach before the 2027 deadline.
• Consult employees: seeking input from employees may strengthen buy‑in and ensure actions are relevant and impactful.
• Engage internally: senior leaders must sign off the plan and line managers will play a crucial role in implementing actions. 
• Gather meaningful data: understanding the causes of your gender pay gap and the experiences of menopausal employees will enable targeted action.
• Aim for more than the minimum: the government encourages employers to go beyond two actions where feasible.

To stay up-to-date with upcoming employer obligations, visit our Employment Rights Act insights and resources page.

This publication is a general summary of the law. It should not replace legal advice tailored to your specific circumstances.

© Farrer & Co LLP, March 2026