Preparing for Gender Pay Gap and Menopause Action Plans

New guidance encourages employers with 250 or more employees to voluntarily publish action plans addressing gender pay gaps and menopause support.

What are gender equality action plans?

Gender equality action plans are designed to help employers take practical steps to improve workplace gender equality and support employees experiencing menopause. By setting out specific actions to address gender pay gaps and menopause support, organisations can demonstrate how they are seeking to create a more inclusive workplace. The plans also provide an opportunity to highlight measures that are already in place to improve gender equality across the workforce.

Employers with 250 or more employees now have the option to produce and publish a voluntary action plan alongside their gender pay gap data.

What should be included in an action plan?

A minimum of two out of 18 actions should be chosen, with at least one addressing the gender pay gap and one supporting employees experiencing menopause. Actions should be considered once issues within the organisation have been identified.

To support employers developing their plans, the guidance includes a range of evidence-informed actions developed through research and expert insight, including work undertaken by the Behavioural Insights Team and the Department for Work and Pensions.

To address the gender pay gap, employers must choose at least one action aimed at reducing the factors that may contribute to pay disparities within their workforce. The guidance includes a number of measures designed to support workplace gender equality and help employers address these issues.

Employers must also choose at least one action to support employees experiencing menopause. This includes both perimenopause and postmenopause. Any actions should be accessible to employees of all ages, recognising that menopause is not experienced only by those within the typical 45 to 55 age range.

Actions may also benefit colleagues experiencing related health conditions such as endometriosis, fibroids and polyendocrine metabolic ovarian syndrome (PMOS). While extending support to other conditions is not a requirement, the guidance encourages measures that may benefit a wider proportion of employees.

A full list of actions can be found here.

How should employers approach their gender equality action plan?

Employers will be asked to identify whether an action is new or in progress, meaning it will either be implemented for the first time or build on work that is already underway. Employers must choose at least two ‘new or in progress’ actions and are encouraged to include any ‘embedded’ actions that are already established within the organisation to provide a more complete picture of their approach.

When submitting an action plan, employers must provide supporting text for each action together with an overall narrative. Supporting text for actions can be up to 100 words and should explain why the organisation has chosen each ‘new or in progress’ action and how progress will be measured. For ‘embedded’ actions, organisations can provide context on how the action was implemented and any outcomes achieved.

The supporting narrative can be up to 200 words and should provide background information on the organisation's approach and priorities. Organisations are also encouraged to make information about their action plan available on their website and provide a link to the relevant page.

Organisations with more than one legal entity should submit a separate action plan for each legal entity with 250 or more employees. This can include different actions for each entity or the same actions applied across the wider group.

When will employers need to publish their action plan?

Employers with 250 of more employees can publish their first action plan at any time during the 2026 to 2027 reporting year, subject to the following deadlines:

• 30 March 2027 – most public authority employers
• 4 April 2027 – private, voluntary and all other public authority employers

Employers operating in the private or voluntary sector must nominate a ‘responsible person’ when submitting their action plan. This individual, typically a director, partner or senior officer, will be responsible for confirming the accuracy of the information submitted.

Although action plans remain voluntary for now, employers should consider identifying organisational issues and developing their approach sooner rather than later. Early preparation can help organisations identify the most appropriate actions for their workforce and ensure they are well placed should action plans become mandatory from Spring 2027 as part of the wider Employment Rights Act 2025 reforms.

For employers seeking guidance on the new equality action plan requirements and support for employees experiencing menopause symptoms, our Employment Law Briefing will take place virtually on Tuesday 6 October. Associate Alex Evans will be joined by Emma Faux, Workplace Menopause Consultant and Founder of MFO Coaching, to discuss what these changes could mean for employers and share practical guidance on creating a menopause-friendly workplace. To book your free place and find out more, follow the link.

If you would like to discuss any aspect of this article further, please contact our Employment team on 0113 244 6100. 

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The information in this article is necessarily of a general nature. The law stated is correct at the date (stated above) this article was first posted to our website.

Specific advice should be sought for specific situations. If you have any queries or need any legal advice, please feel free to contact Wrigleys Solicitors.