Guide
Equality and menopause action plans for large employers
Requirements for mandatory gender pay gap action plans and menopause support action plans for employers with 250 or more employees, introduced by the Employment Rights Act 2025. Expected to commence in 2027.
The Employment Rights Act 2025 introduces two new mandatory action plan requirements for employers with 250 or more employees:
- Gender equality action plans - setting out steps to address gender pay disparities
- Menopause action plans - setting out workplace support for employees experiencing menopause
Both requirements are expected to commence in 2027, subject to regulations setting out the detailed content and format requirements. Employers should start preparing now.
These obligations apply to the same employers who must already report gender pay gap data. If you have fewer than 250 employees, these requirements do not currently apply to you.
Gender equality action plans
Currently, employers with 250+ employees must report their gender pay gap data but are only encouraged to publish action plans explaining what they will do about it. The ERA 2025 makes action plans mandatory.
How this builds on existing reporting
The existing gender pay gap reporting requirement (six mandatory calculations, published annually) remains unchanged. The action plan is an additional requirement that must be published alongside the data.
The regulations will specify the content requirements for action plans, but employers should expect to address:
- Root causes: Analysis of why the pay gap exists in your organisation
- Recruitment: Steps to attract diverse candidates, particularly to higher-paid roles
- Progression: How you support women's career progression and reduce barriers
- Retention: Policies that help retain female talent (flexible working, parental support)
- Targets: Measurable goals and timescales for reducing the gap
- Accountability: Who is responsible for delivery at senior level
Menopause action plans
This is an entirely new statutory obligation. There is no existing reporting requirement to build on, so employers may need to start from scratch.
Preparing your menopause action plan
While waiting for detailed regulations, employers can begin preparing by:
- Assess current provision: What support do you already offer? Survey employees (anonymously) to understand needs
- Develop or update policy: Create a standalone menopause policy or integrate menopause into health and wellbeing policies
- Train line managers: Ensure managers can have supportive conversations and know what adjustments are available
- Review workplace environment: Consider temperature control, ventilation, access to cold water, and toilet facilities
- Adjust absence management: Consider recording menopause-related absence separately from general sickness to avoid triggering absence management procedures
- Provide support resources: Occupational health referrals, employee assistance programmes, and signposting to NHS resources
Timeline and next steps
- Now: Review existing gender pay gap data and voluntary action plans
- Now: Assess current menopause support provision and identify gaps
- 2026: Watch for draft regulations setting out action plan content requirements
- 2027 (expected): First mandatory action plans due alongside annual gender pay gap reports
Ethnicity and disability pay gap reporting: The government has also committed to introducing mandatory ethnicity and disability pay gap reporting through a separate Equality (Race and Disability) Bill. This is expected to follow a similar 250+ employee threshold but is not part of the ERA 2025.