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What you need to know as your business grows - employment thresholds, reporting requirements, and growth support.
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.
Employers with 250 or more staff must publish two action plans by 2027: one to reduce gender pay gaps and another to support employees experiencing menopause. Start preparing now. These plans must be published alongside your annual gender pay gap report.
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The Employment Rights Act 2025 introduces two new mandatory action plan requirements for employers with 250 or more employees:
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.
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.
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:
This is an entirely new statutory obligation. There is no existing reporting requirement to build on, so employers may need to start from scratch.
While waiting for detailed regulations, employers can begin preparing by:
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.