Gender Equality Action Plans: Changes under the Employment Rights Act 2025

By Rachel Davis

Principal Associate

The Employment Rights Act 2025 (“ERA”) introduces a new requirement for large employers (250+ employees) to publish Gender Equality Action plans.  These plans must show how the employer is taking action to address gender pay gaps and to provide menopause support.

Voluntary reporting starts in April 2026 with mandatory reporting in 2027.

The UK Gender Pay Gap is the difference in average earnings between men and women in the workplace. It persists due to factors including disproportionate caregiving responsibilities, flexible working arrangements which disproportionately impact women, occupational segregation, and under-representation of women in senior roles.  According to the trade union body’s analysis of official pay data, the gap between men and women’s average wages stands at 12.8%.  This means that an average female employee effectively works for 47 days of the year ‘for free’.

Since 2017, large employers are required to publish specific gender pay gap data annually on a publicly available government website. Whilst this requirement has improved transparency in respect of disclosure, many businesses have not yet put in place effective action plans to address the gap.

Under the ERA, large employers will be required to publish Gender Equality Action Plans detailing the evidence-based actions they are taking to improve gender equality, by addressing gender pay gaps and providing support for those going through menopause.  These plans are designed to move beyond reporting and towards accountable, measurable strategies that aim to close pay gaps and embed inclusive workplace practices.

The transition from a voluntary to mandatory requirement in 2027 is intended to give employers time to integrate action planning into broader equality, diversity and inclusion frameworks.

With voluntary action plans required from 6 April 2026, employers should begin planning now by reviewing pay structures, promotion criteria, flexible working arrangements and recruitment practices.

With effective planning employers can use these reforms not only to meet legal obligations, but to strengthen organisational culture , improve talent attraction and employee retention and contribute to greater equality at work.