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From 06 April 2026, large employers will be encouraged to publish equality action plans (EAPs) outlining how they are tackling gender inequality, including addressing the gender pay gap and supporting staff experiencing the menopause. This will be voluntary at first, becoming a mandatory requirement in spring 2027, with further detail explored in this article.

What is Changing?

The Employment Rights Act introduces a new power which allows regulations to be made requiring employers to publish EAPs.

The introduction of EAPs builds on existing duties under the Equality Act 2010, which already requires large employers (250+ employees) to publish annual gender pay gap data on a publicly available government website. EAPs will go further, requiring employers to set out how they will address the gender pay gap in their organisation, and support employees experiencing menopause – recognising the substantial impact this can have on women’s participation and progression at work.

Action plans will need to set out evidence-based actions which an employer is taking to improve gender equality amongst employees. The intention of EAPs is to link reporting with practical steps for improvement.

Employers will publish plans on the gender pay gap reporting service.

When Will the New Requirements Apply?

April 2026 – Voluntary Adoption

From 06 April 2026, large employers will be encouraged to voluntarily develop and publish EAPs. This early adoption period is intended to give organisations time to prepare for the mandatory duty and introduce processes gradually.

Spring 2027 – Mandatory Reporting Expected

From spring 2027, regulations will require all large employers (250+ employees) to:

• Publish an Equality Action Plan (this is expected to be an annual requirement)
• Detail the evidence-based actions they are taking to reduce gender inequality; and
• Detail how they support employees experiencing the menopause

What Will Employers Need to Include?

Whilst detailed regulations and guidance are still awaited, the Government has indicated that EAPs will need to be evidence based and therefore action plans may include:

• Analysis of gender pay gap data and commentary
• Clear, measurable actions to close pay gaps
• Organisational policies and action taken in respect of menopause support
• An assessment of the workforce to identify barriers to equality

The Government intends to provide guidance and information on effective actions supported by evidence, and further, to support employers in selecting actions. Whilst smaller organisations are not required to develop an action plan, practical guidance will be made available to all, allowing organisations of all sizes to have sight of evidence highlighting effective steps which can be taken.

Why Should Employers Act Now?

The 2026 voluntary phase is strongly encouraged, as this will prepare organisations ahead of the mandatory implementation, and ensure that at the date of mandatory implementation, action plans are meaningful and aligned with the new requirements. Early implementation demonstrates a proactive commitment to equality and transparency.

In addition to this, employers will reduce the risk of equal pay or discrimination challenges by evidencing structured mitigation steps. In time, this will enhance recruitment and retention, particularly of female talent.

How Can Employers Prepare?

1. Review your gender pay gap data – Identify priority areas and underlying causes.

2. Consider existing gender pay gap action – Identify any gender pay gap action which the organisation has in place, and = whether this can be updated or improved upon with reference to data. Begin to think about what you could include in an action plan.

3. Strengthen menopause support – Employers should ensure they have a menopause policy in place, and that this is up to date. Organisations should also consider providing training, or refresher training to management and the wider workforce, to raise menopause awareness. It will be necessary to consider whether there are any additional measures which the organisation could take to support workers going through the menopause.

Outsourcing

Whilst the timing of the change will depend on broader pay gap reforms, in 2027 employers can also expect to see the introduction of a gender pay gap outsourcing measure, extending existing pay gap reporting to cover outsourced workforces. The Government’s aim is to ensure that employers cannot hide inequality by contracting out services.

Large employers will be required to state which companies they outsource to, and as such, can be held accountable for gaps in those organisations. This will encourage them to play an active role in strengthening gender equality across the organisations they engage with.

Conclusion

Equality action plans represent a significant shift from transparency to accountability in gender equality reporting. Whilst voluntary from April 2026, large employers should begin preparing now for mandatory reporting in spring 2027. Taking early action will not only ensure compliance but also support a fairer, more inclusive workplace.

If you require any advice on preparing an equality action plan, please feel free to contact AfterAthena (part of the Napthens Group) who are able to offer 30 minutes of free advice to QCS members.