Will the requirement to publish action plans close the UK's gender pay gap?

Background

Gender pay gap reporting was introduced as a legal requirement for large employers in 2017, with the first mandatory reports published from 2018. Progress is being made but it's painfully slow. Recent data indicates that in April 2025 median pay for all employees was 12.8% less for women than for men. 

Before the election the Labour Party said it would “go further and faster to close the gender pay gap” by requiring large firms to develop, publish and implement action plans. 

It also said it would force large employers to produce menopause action plans. 

The new legal framework

Section 33 of the ERA 2025 amends the Equality Act 2010. Once in force (via separate regulations), employers with 250 or more employees must develop and publish an equality action plan setting out the steps it plans to take to reduce its gender pay gap, and to support employees experiencing menopause.

When does this come into force?

The government hasn't published regulations which will bring this into force. However, it has said that from April 2026, you can, if you wish, voluntarily publish your action plans for the 2026–27 reporting year. But from 2027 you must do so. 

You must publish this information before the deadline for publishing your gender pay gap data, namely: 

• 30 March 2027 - public authority employers; and
• 4 April 2027 - private sector. 

If you don't publish your plans, you are likely to be named and shamed, and may face other enforcement action. We'll know more once regulations have been published - which may not be until next year. 

Interaction with gender pay gap reporting

The way in which you have to report your gender pay gap won't change. You must still publish annual data showing the differences in pay and bonuses between the men and women you employ. 

The key development is that you must publish your action plans alongside your gender pay gap data on the existing government reporting portal. 

What should your action plan say? 

You must commit to take at least one action to reduce your gender pay gap and at least one action to support employees experiencing menopause. 

The government has published guidance to help with this, together with a list of recommended action plans. 

These are grouped into five key themes, and each section has links to separate detailed guidance:

• Recruitment: provide inclusive job descriptions, encourage applications from a range of candidates, reduce unconscious bias in recruitment processes, use fair and structured interview techniques, advertise leave policies in job adverts and advertise flexible working arrangements.
• Development and promotion: automatically consider eligible employees for promotion, encourage development, and provide mentoring, sponsorship and other development programmes.
• Building organisational diversity: set targets to improve gender representation and review workforce demographics.
• Transparency: promote openness around pay structures, promotion criteria, and reward systems, and enhance/promote flexible working and leave policies.
• Menopause and women’s health support: provide training to managers, offer occupational health support, set up menopause support groups, make workplace adjustments, undertake menopause risk assessments, and review relevant policies and procedures.

Although the list is extensive, the government doesn't expect you to adopt every measure. It has set the statutory minimum you are required to do to give organisations the flexibility they need to reflect their size and the sector they work in.

Menopause as a workplace equality Issue

Whilst many employers are much more aware of the impact menopause can have on its female staff, the government points to evidence that many women continue to leave their roles because they are not receiving the support they need.  

The government hopes that forcing employers to create action plans will help to normalise and focus menopause as a workplace issue rather than a personal one, and help to embed support at an organisational level, rather than leaving it to individual women to ask for adjustments.

Enforcement and reputational risk

It doesn't look as though you will face specific sanctions if you don't deliver the actions set out in your plans. But employees, unions, clients and the public may may challenge you because the information will be in the public domain. The government believes this will put sufficient pressure on employers to drive compliance and see improvements.  

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