Equality Action Plans – What employers need to know now

The government has also published new step-by-step guidance for employers on the six steps to follow when creating an action plan to reduce their gender pay gap and to provide menopause support for employees. The six steps are: 

• Step 1: Understanding the issues in the organisation and how to diagnose the gender pay gap using the data. 
• Step 2: Choosing a minimum of two actions from a list of 18 prescribed actions, one to address the gender pay gap and one for menopause support.  For each action selected employers will need to explain if it is new/in progress or an embedded action i.e. it is already an established part of the employer’s working practice.  Employers must choose at least two actions that are new/in progress.
• Step 3: Writing a supporting text for each action (up to 100 words) and a supporting narrative for the overall action plan (up to 200 words). 
• Step 4: Submitting the action plan on the government's gender pay gap service. 
• Step 5: Tracking the outcomes of the action plan. 
• Step 6: Reviewing the action plan annually.  Subject to legislation, it is expected that employers will need to carry out an interim progress review one year and two years after submitting the mandatory action plan, with a more detailed review of progress three years after submission.

The list of actions to address the gender pay gap includes: 

• Recruitment measures (such as inclusive job descriptions, reducing unconscious bias in CV screening and advertising flexible working arrangements).
• Developing and promoting staff. 
• Building diversity into the organisation by setting targets. 
• Increasing transparency in relation to pay, promotions and rewards as well as flexible working and leave policies.

The transparency measures touch on some of the requirements in the EU Pay Transparency Directive. With the Directive’s implementation deadline fast approaching on 7 June 2026, multi-national employers mindful of new obligations in their EU operations may want to align their pay transparency policies across the organisation to meet the requirements of both the Directive and UK equality action plans to avoid inconsistencies and operational challenges of having different processes and policies within the workforce.  (For more information see our EU Pay Transparency Directive Hub here).  

It is also worth noting that the Employment Rights Act 2025 will, in time, require employers to name the companies from which they receive outsourced work to hold employers accountable for gender pay gaps that exist in those organisations, although there is no timeline for this measure yet.  (See government factsheet: Equality Action Plans and Outsourcing). 

The equality action plan must include at least one action that supports employees experiencing menopause.  The government guidance explains that any steps to provide menopause support should be accessible to employees of any age experiencing menopause, including perimenopause and post-menopause.  Although not a requirement of action plans, the government says it supports employers expanding actions to benefit other health conditions related to menstrual health which can impact wellbeing such as endometriosis, fibroids and polycystic ovary syndrome.

The list of actions includes ideas such as:

• Training managers to support employees experiencing menopause.
• Offering occupational health advice which could help employees manage health conditions.
• Setting up menopause support groups and networks.
• Offering workplace adjustments such as temperature control and ventilation, suitable uniforms and rest areas.
• Conducting a menopause risk assessment for the workplace to identify and put in place any appropriate adjustments.
• Reviewing policies and procedures to meet the needs of employees experiencing menopause.

In its response to the consultation on mandatory ethnicity and disability pay gap reporting the government has confirmed that it intends to introduce the requirement for large employers with 250 or more employees.  The reporting requirements will largely mirror the gender pay gap reporting requirements including reporting on the same six pay gap measures using the same reporting dates and online service.  Key takeaways include:

• Ethnicity pay gap reporting will require employers to report a binary comparison of white (including white other) with all other ethnic groups combined as a minimum but also to aggregate to five ethnic groups where possible. In practice, this means that individual ethnic groups would be aggregated into one of five broader ethnic groups: White; Asian or Asian British; Black, Black British, Caribbean or African; mixed or multiple ethnic groups; other ethnic groups. There will be a threshold for employees for each group to protect anonymity. Policy work is ongoing to determine the most appropriate threshold. 
• Disability pay gap reporting will require employers to report a binary comparison, comparing disabled employees with non-disabled employees, using the Equality Act 2010 definition of disability. Again, there will be a threshold for employees for each group to protect anonymity, but policy work is ongoing to determine the most appropriate threshold. 
• Action plans will also be mandatory. The government is aiming to harmonise the approaches so that employers can produce a single equality action plan on the same service covering sex, race (including ethnicity) and disability, when all the reporting requirements are in force. This recognises that some actions may be beneficial for multiple groups (for example, flexible working). 
• The government intends to harmonise the approach to enforcement across gender, ethnicity and disability. As it stands, the EHRC is responsible for enforcing reporting annually. 

There is no timeline for introducing mandatory ethnicity and disability pay gap reporting yet. The government has published draft clauses to be included in legislation, but it is not clear precisely how and when these will be brought into force.  We can also expect to see guidance to support employers with the proposed new reporting requirements in due course.

Large employers should consider the new requirements for equality action plans and start to prepare for the changes to come.  Businesses should audit pay gap data now to identify any disparities and to ensure accurate reporting.  Employers may want to consider ways to improve current data capture in preparation for mandatory reporting and use the voluntary process for 2026-2027 as a practice run to help identify issues.  This is also an opportunity to think about the actions to take to try to reduce the gender, ethnicity and disability pay gaps and ways in which the business can support employees experiencing menopause.  Employers may already be taking action to address the gender pay gap.  This is a good opportunity to ensure those actions are monitored and documented to track progress.  This will help to evaluate the actions taken to give a better understanding of whether they are effective at reducing pay gaps.