What is the current situation?

Employers with 250 or more employees must publish an annual gender pay gap report that shows the average and median pay differences between male and female employees.

There is currently no legal requirement to publish an action plan, although many employers choose to do so voluntarily.

So what’s changing and when?

From 2027, the Employment Rights Bill will require employers with 250 or more employees to develop and publish equality action plans showing what steps they are taking in relation to certain prescribed gender equality matters. This will include explaining what action the employer is taking in respect of its gender pay gap and how it is supporting workers during the menopause. 

Regulations will provide how often employers will need to publish their equality action plans. 

In addition, regulations will require employers to name the providers they contract with for outsourced workers in their gender pay gap reports. The implementation date for this has not yet been decided.

(The Government separately plans to include ethnicity and disability pay gap reporting obligations for large employers in a new Equality (Race and Disability) Bill.)

There are likely to be consultations on all these matters.

What you need to do now

  • Consider if you are likely to have 250 or more employees in 2027. If so, the new law on equality action plans will apply to you, and you should consider taking the steps below to prepare. If you are unlikely to meet the 250 employees threshold in 2027, consider whether, as a matter of good practice, you wish to develop an equality action plan in any event.
     
  • Review your gender pay gap data by examining recruitment, promotion and pay information.
     
  • Consider any gender pay gap action plan you already have in place.  Does it need updating? Can it be improved? If you don’t have one yet, start thinking about what you’re doing to improve gender equality, and what evidence your actions are based on.
     
  • Start thinking about the impact of naming providers of outsourced workers in your gender pay gap report. What is the gender pay gap of your providers? If you yourself are a provider, how might your own gender pay gap figures affect your ability to gain or retain contracts? 
     
  • Do you have a menopause policy and/or a menopause action plan? If so, have you reviewed them recently? Consider whether your managers and wider workforce would benefit from menopause awareness training or a refresher course. Are there any additional measures you could take to support workers going through the menopause?

How Make UK can help you

Whether you’re already getting support from us or you’re just starting to explore your options, we’re here to help you plan for the Employment Rights Bill changes and protect your business.

Already getting support from Make UK? 

You’ll receive updates from us as key legal changes come in, so you can stay compliant and up to date.

Detailed HR and employment law guidance can also be found in the HR & Legal Resources section of our website.

If you’ve got questions or need advice, your Make UK legal adviser is on hand to help, including with HR policy reviews and updates.

Our HR and legal consultants can also provide hands-on support with any projects as you prepare for these changes. We can provide menopause awareness training for both managers and your wider workforce. We can also help you understand the diversity profile of your workforce, including carrying out pay gap audits, assisting with action plans, and providing training on unconscious bias to support your recruitment.

You can also shape future policy. We speak regularly with Government and feed into consultations, using input from businesses like yours. 

New to Make UK?

You don’t have to face the changes alone. Whether you need quick input or ongoing support, we can help you however works best for your business.

One-off, practical support

If you want focused help to get ready for the changes:

  • Project support: Hands-on help from our HR and legal consultants to get the right steps in place and stay compliant
     
  • Right Track Review (coming soon): A focused, in-business audit with clear, practical steps to keep you compliant
     
  • ERB Hotline (coming soon): Real-time access to legal specialists when you need quick answers about the Employment Rights Bill
     

Ongoing employment law and HR support


For longer-term support, our retained service includes:

  • Direct access to employment law experts
     
  • Regularly updated HR policies and templates
     
  • Advice for both day-to-day issues and bigger picture planning
     
  • The chance to help shape Government policy
     

Not sure what you need?

Call 0808 168 5874 or email and we’ll help you work it out.

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06/08/2025

Note: The Employment Rights Bill is still completing its passage through Parliament and its content has not yet been finalised. In addition to possible amendments to the Bill, many of the reforms require consultations and regulations before implementation. Our Spotlight Guides reflect our current understanding of the likely final content, but this may change. The information provided in this Spotlight Guide is for general informational purposes only and should not be considered legal advice.