Employment Law Guide 2026: Equality action plans

Large employers employing 250 or more employees are already required to report on their gender pay gap and to publish their gender pay gap information on their website, as well as on a Government website.

Although employers have been encouraged to go beyond reporting and to implement action plans to reduce inequality, there are currently no legal obligations for them to do this. This is due to change from 2027. The ERA 2025 allows regulations to be made requiring large employers to develop and publish an equality action plan showing the steps they are taking to advance equality between male and female employees. This will include addressing the gender pay gap, as well as supporting employees going through menopause. Large employers are encouraged to develop equality action plans on a voluntary basis from April 2026. We expect that Equality Action Plans will need to be published annually on a Government-run portal (similar to the current gender pay gap reporting obligations). It is not known if there will be sanctions for a failure to publish a report.

Implications/Action points

• The scope and implementation of action plans could become grounds for dispute in discrimination claims
• Where your gender pay gap reporting reveals a gender pay gap, consider what action you can take to reduce/eliminate pay inequality
• Consider your workforce profile and demographic and what steps you can take to support employees going through menopause.