Last reviewed: 19.11.2025
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?
Employers with 250 or more employees will be required 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. These measures are expected to be introduced on a voluntary basis in April 2026, before coming into force in 2027.
Regulations will set out the detailed requirements and 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 indicated.
(The Government separately plans to include ethnicity and disability pay gap reporting obligations for large employers in a new Equality (Race and Disability) Bill.)
What you need to do
If you are likely to have 250 or more employees in 2027, you should consider taking the steps below. 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? What are you doing to improve gender equality, which you could include in an action plan, and what evidence are your actions based on?
- Consider 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 we can help
- Sign up to our updates as the legal changes come in, so you can stay compliant and up to date.
- We have detailed HR and employment law guidance, template policies and letters on our website in the HR & Legal Resources section, which will be maintained as the changes come into force.
- Our team of employment lawyers is happy to help if you’ve got questions or need advice. And if you need hands-on support with any projects as you prepare for the changes, our HR and legal consultants can work with you to get the right steps in place and stay compliant.
- Use our ERB enquiry line ([email protected]) for real-time access to legal specialists when you need quick answers about the Employment Rights Bill.
- Ask about our Right track review (coming soon): A focused, in-business audit with clear, practical steps to keep you compliant.
- You can also shape future policy. We speak regularly with Government and feed into consultations, using input from businesses like yours.
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 day-to-day issues and bigger picture planning.
- The chance to help shape Government policy.
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