Starting in April 2026, employers with 250 or more staff will have the option to prepare and share a voluntary action plan alongside their gender pay gap statistics, as set out in the Employment Rights Act 2025 (ERA 2025). From spring 2027, these action plans are expected to become mandatory, depending on further legislation. On March 4, the Office for Equality and Opportunity released a list of recommended, evidence-based steps that employers can incorporate into their plans to support effective action (Action plans: list of actions – GOV.UK). The government also published an overview on creating an action plan (Overview – GOV.UK). This post looks at the list of actions and what those employers who wish to submit an action plan should be doing.
What is the purpose of the action plans?
The government has set out that the purpose of the action plans is to support employers to take effective action to improve workplace gender equality. Action plans will show the steps that employers are taking to both reduce their organisation’s gender pay gap and support employees experiencing menopause.
The government suggests that as part of developing an action plan, employers must choose at least one action to address their gender pay gap and one action that supports employees experiencing menopause (which may also benefit employees experiencing other health conditions related to menstrual health which can impact their wellbeing and may disadvantage them in the workplace).
The government is clear that it is important to obtain organisation wide support in the successful development and implementation of the action plan. This requires senior managers to sign off on the actions and for input to be obtained from a wide range of employees and stakeholders when developing the plan.
Producing the action plan
The government has confirmed that additional guidance will be published in April 2026 which will cover the steps employers should take when developing their action plan. These steps will include:
- Understanding the issues in the organisation: This means analysing the data collected to choose the right actions for the organisation.
- Selecting the actions
- Submitting the action plan
- Tracking the outcomes of the
- Reviewing the plan
The content of the action plan
The government’s publication of the list of actions is detailed and is divided into five separate headings. Each of the actions, explains its purpose and why organisations may find it helpful to apply that action.
- Recruiting staff
- Make job descriptions inclusive: To attract a more diverse pool of applicants. This includes using neutral language and titles; reviewing the requirements for the role; focusing on accessibility; and inclusion and using artificial intelligence responsibly (ensuring that ensuring that AI outputs do not repeat gender biases.
- Encourage applications from a range of candidates: This can include working with networks to advertise roles to under-represented groups; providing feedback to those who just missed out on a job to encourage them to apply for other roles; and offering paid “returnships”.
- Reduce unconscious bias in CV screening; This can include using an anonymised application form and CV template and enabling a screening mode in the applicant tracking system.
- Use fair and structured interview techniques: This includes setting up the panels correctly; planning the questions; using clear scoring; and training staff.
- Developing and promoting staff
- promotion: This includes allowing employees to opt out of a promotion process rather than putting themselves forward but ensuring that there are no consequences if they opt out or withdraw.
- Encourage employee development through actionable steps: This includes managers giving effective and actionable feedback which can help staff to reach the next level.
- Building diversity into your organisation
- Increasing transparency
- Increase transparency for pay, promotion and rewards: This includes identifying the processes; taking to employees and holding managers accountable.
- Supporting women with health conditions and menopause
- Train managers to support employees experiencing menopause including looking at the law, the symptoms, how to encourage employees to raise concerns and what support and adjustments could be made.
- Offer workplace adjustments for employees experiencing menopause. The types of adjustments can include flexible working hours; access to private rest areas; ergonomic office furniture; specialist health advice and environmental settings, such as the temperature in the workplace.
- Review policies and procedures to meet the needs of employees experiencing menopause such as flexible working; workplace adjustments and leave provisions.
Publication of the action plan
Action plans will be submitted and published on the gender pay gap service and will be public along with an organisation’s gender pay gap data. The section of the website to publish the action plan will go live following the 2026 gender pay gap reporting deadlines. Organisations may also publish their action plans on the organisation’s website.
Organisations can voluntarily produce and publish their first action plan any time during the 2026 to 2027 reporting year. It must be published by 4 April 2027 – for private, voluntary and some public authority employers and 30 March 2027 – for most public authority employers.
Conclusion
On some of the actions the government has indicated that they have less high-quality evidence supporting the action than for others, but that they are building their evidence base and will continue to review and update the actions. It is also clear that employers must track the progress of the actions they select and the guidance gives advice on how each action can be tracked. Employers should start considering their gender pay gap and which actions they should adopt to improve the workplace gender equality.