Key takeaways
Voluntary gender equality action plans launch in April 2026
Large employers must publish mandatory gender equality action plans from Spring 2027.
Plans must address gender pay gap and menopause
Employers must choose actions on gender pay gap and menopause support.
Strong leadership and stakeholder input essential
Guidance stresses senior buy in and meaningful engagement with employee groups.
The Employment Rights Act 2026 contains provisions placing a new duty on large employers (250+ employees) to publish gender equality action plans (GEAPs), showing the steps that they are taking regarding addressing the gender pay gap and how they are supporting employees going through the menopause. The government has recently confirmed that GEAPs will be introduced on a voluntary basis from April 2026 and will become mandatory from Spring 2027.
Employers on the gender pay gap reporting service will have the option to voluntarily produce and publish a voluntary action plan alongside their gender pay gap data for the 2026/27 reporting year. To encourage this voluntary participation, the government has published new guidance Creating an action plan: guidance for employers. The guidance published includes:
An overview of what the GEAP duty will cover;
Lists of evidence-informed actions to reduce the gender pay gap and support employees experiencing menopause, which focus on recruiting, developing and promoting staff, building diversity into an organisation, increasing transparency, and supporting employees experiencing menopause; and
Links to supporting research concerning the main predictors of the gender pay gap, how to improve gender equality in the workplace, and menopause in the workplace.
With regards to developing an GEAP, the overview confirms that employers must:
choose at least one action to address their gender pay gap; and
choose at least one action that supports employees experiencing menopause (including perimenopause). The guidance notes that, although expanding actions to benefit other conditions is not a mandatory requirement, this menopause-related action may also benefit employees experiencing other menstrual health conditions such as endometriosis, fibroids and polycystic ovary syndrome.
The guidance recognises that organisation-wide support is critical to the successful development and implementation of an GEAP. The buy-in of senior leaders is essential and managers will play a crucial role in implementing an effective GEAP. It also recommends employers discuss the development of the GEAP with stakeholders including trade unions and relevant employee networks, because their feedback can help identify which actions could have the greatest impact. More detailed guidance on developing voluntary GEAPs is expected to be published in April 2026.
When it is brought into force in Spring 2027, the mandatory duty will apply to large employers (those with 250 or more staff). Regulations will provide further details concerning mandatory GEAPs in due course, including the required content, the form and manner in which a GEAP is to be published, when and how frequently a GEAP is to be published or revised (which will not be more frequently than annually), requirements for senior approval before a GEAP is published, and how non-compliance with the mandatory duty will be enforced.
