The Government has published detailed guidance for employers with 250 or more employees on creating a gender equality action plan.
Producing a gender equality action plan is voluntary from 6 April 2026 but will become mandatory from Spring 2027.
The requirement to produce a gender equality action plan sits alongside the existing obligation to publish annual gender pay gap data. Action plans will set out the steps organisations are taking to address gender pay gaps and support employees experiencing menopause.
It includes proposals for specific steps to identify action for menopause support.
The full guidance can be found at Creating an action plan: guidance for employers.
The six steps
The Government published step-by-step guidance on creating an action plan on 7 April 2026, supplementing an overview published on 4 March 2026.
- Step 1 – Understand the issues in your organisation
- Step 2 – Choose your actions
- Step 3 – Write a supporting narrative
- Step 4 – Submit your action plan
- Step 5 – Track the outcomes of your actions
- Step 6 – Review your plan
Step 1: Understand the issues in your organisation
The guidance explains how employers can identify and analyse evidence to find the causes of their gender pay gap, and that they should talk with employees to understand how they may be affected by menopause at work. Good potential sources of evidence include: workforce data, employee networks, senior leaders, and stakeholders.
Employers are told to look at every step of the employee lifecycle to determine where a gender pay gap is present, and to talk to a wide range of staff, manager and employee groups during the process. The analysis should be repeated before, during and after starting the action plan using the same metrics to allow comparison of progress.
The guidance emphasises the importance of the support of senior leadership and early employee involvement to improve prioritisation and buy-in to the process.
Step 2: Choose your actions
Employers must choose a minimum of two actions from a list of 18 actions. One must address the employer’s gender pay gap, and one must support employees experiencing menopause. For each action, the employer must confirm if it is:
- New or in progress – this means you will be working on it for the first time or building on something you are already doing.
- Embedded – this means it is already an established part of your working practice.
You must choose at least two actions that are ‘new or in progress’.
The 18 available actions are categorised into five key areas, each with guidance on its purpose, benefits and steps to implementation.
- Recruiting staff
- Developing and promoting staff
- Building diversity into your organisation
- Increasing transparency
- Supporting employees experiencing menopause
Step 3: Write a supporting narrative
For each action selected, employers must add further details about why they selected the action, and how they are tracking and understanding the impact of the action on gender equality in their organisation
For ‘embedded’ actions, employers can add further details about how the action was implemented and what the results have been.
Employers can also add an overall supporting narrative with background information.
Employers will not be able to upload files such as CSVs or PDFs to the action plan. However, when they create their action plan on the gender pay gap service, they will be asked to link information in their plan to the relevant page on their organisation’s website
Step 4: Submit your action plan
Employers will have to sign into the Government’s gender pay gap service to submit their action plan.
Step 5: Track the outcomes of your actions
Employers should measure and monitor the progress of their action plan to show accountability and commitment to their goals, provide early and ongoing insights, and provide data to help shape the implementation of an action.
Each action guidance page contains guidance on suggested metrics to monitor progress.
Step 6: Review your plan
Details of the review process is subject to legislation. It is expected that employers will need to conduct an interim review one and two years after submission of their mandatory plan in spring 2027 and will need to conduct a more detailed review three years after submission of the mandatory plan.
Employers will be able to revise their list of actions at the review stage but must have two ‘new or in progress’ actions at any time.
Commentary
The guidance sets out a clear process for employers to identify and track the gender equality related issues in their organisation. The emphasis placed on ongoing monitoring and documentation of the process and outcomes of the action plans is a clear indication of the level of structure that will be required when the action plans become mandatory in 2027.
Employers should make use of the period before submission becomes mandatory to assess whether their organisation has the structures in place that will enable them to understand and track the gender pay gap and menopause related issues faced by their employees.
How we can help
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For more information about how we can help, please contact us.
