Equality and menopause action plans for large employers

The Employment Rights Act 2025 requires employers with 250 or more employees to publish two action plans. A gender equality action plan sets out the steps you will take to address gender pay disparities. A menopause action plan sets out the workplace support you give employees experiencing the 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 apply to you.

Gender equality action plans

Until the duty starts (expected in 2027), employers with 250+ employees must report their gender pay gap data and 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. There is no fine for failing to publish, but the Equality and Human Rights Commission can take enforcement action, including court orders.

The regulations will specify the content requirements for action plans, but employers should expect to address:

• why the pay gap exists in your organisation
• steps to attract diverse candidates, particularly to higher-paid roles
• how you support women's career progression and reduce barriers
• policies that help you keep female staff, such as flexible working and parental support
• measurable targets and timescales for reducing the gap
• who at senior level is responsible for delivery

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:

1. Check what support you already offer, and survey employees anonymously to understand their needs.
2. Create a standalone menopause policy, or build menopause into your health and wellbeing policies.
3. Train line managers to have supportive conversations and to know what adjustments are available.
4. Review temperature control, ventilation, access to cold water and toilet facilities.
5. Consider recording menopause-related absence separately from general sickness, so it does not trigger absence management procedures.
6. Offer support such as occupational health referrals, an employee assistance programme and signposting to NHS resources.

Timeline and next steps

• Review your gender pay gap data and any voluntary action plans.
• Assess your menopause support and identify gaps.
• Watch for draft regulations setting out what action plans must contain.
• Expect the first mandatory action plans to be due in 2027, alongside your annual gender pay gap report.

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.