Gender Equality Action Plan

Gender Equality Action Plan

Employment Rights Act 2025

What are the Steps Employers should take to Build a Gender Equality Action Plan?

Under section 33 of the Employment Rights Act 2025, which amends the Equality Act 2010, large employers with 250 or more employees will be required to develop and publish equality action plans showing what steps they are taking with regards to gender equality and to publish information relating to their plans. Whilst it was encouraged for Employers to prepare the same from April 2026, they will not become Mandatory until April 2027 (March 2027 for public authority employers).

The purpose of these equality action plans are to assist employers to take effective action to improve workplace gender equality. Action plans should show:

• Reduce the organisation’s gender pay gap; and
• Support employees who are currently experiencing the Menopause

Step-by-Step Guidance on Creating Action Plans:

There are six guidance documents, all of which are housed on a collection page which also contains the overview guidance on the government website.

The following steps are set out below:

Step 1: Understand the Issues

Employers are encouraged to review their accessible information to identify the factors contributing to their gender pay gap and speak with employees to learn how menopause may be affecting their experience at work. The guidance outlines:

• Why evidence matters and the most useful sources of information, such as workforce data, employee networks, senior leaders and other key stakeholders.
• How to diagnose the gender pay gap by assessing each stage of the employee lifecycle.
• How to understand employees’ needs by engaging directly with staff, and why it’s important to repeat this analysis before, during and after implementing an action plan to track progress over time.
• The importance of organisation – wide engagement, including involving senior leaders and managers early through consultation and training.

Step 2: Choose your Actions

Employers must select at least two actions in total for their action plans. One action must focus on reducing the gender pay gap, and another must focus on supporting employees experiencing menopause.

For each action, employers must clearly specify whether it is:

• New or in progress – an initiative the employer is undertaking for the first time, or an enhancement of an existing measure.
• Embedded – an action that is already fully established within the organisation’s standard working practices.

Employers must ensure that at least two of the chosen actions are new or in progress.

Step 3: Write a Supporting Narrative

Each action plan must contain:

• Supportive 100 word text for each action plan explaining why it was chosen and they the Employer intends to track its progression. In terms of embedded actions, employers should explain how these actions became an established part of working practice.
• A 200 word narrative supporting the overall plan (which could include the Employer’s objectives for gender equality.)

Employers are encouraged for the abovementioned responses to be listed on their websites and provide links to relevant pages when they submit their action plans.

Step 4: Submitting your Action Plan:

In order to submit an action plan, Employers must sign into the Gender Pay Gap Service via the Government Website. Employers are obligated to elect a “responsible person” in order to approve the action plan before submission, albeit this is not necessary for most public authority employers.

Step 5: Track your Outcome(s)

Employers must test whether progress against each action is happening as they intend for such provision.

The guidance sets out:

• Why employers should track progress to ensure their actions are having the intended impact.
• How progress can be measured, using relevant data and consistent monitoring methods.
• How to identify variations in outcomes across different groups within the workforce.
• How to evaluate the effectiveness of such action plan and determine whether further adjustments are needed.

Step 6: Reviewing the Plan

As discussed earlier, Action Plans will become mandatory from Spring 2027. After this, the Employer will be obligated to review and update their action plans every year.

Legislation will determine what employers are required to do at each review stage. As matters stand as at the date of this Article:

• An interim review must take place one year and two years after the mandatory action plan is submitted.
• A more detailed review will be required three years after submission.

Employers may update their list of actions at the end of each year. They must always be actively working on at least two actions. If an action changes status (for example, moving from “new or in progress” to “embedded” or the reverse), or if an action is removed, a new action must be added to the plan and the system must be updated accordingly.

For further information, please contact please contact a member of our Employment law team at: –

Kerseys Solicitors in Ipswich at [email protected] or telephone 01473 213311 or
Kerseys Solicitors in Felixstowe at [email protected] on 01394 834557 or
Kerseys Solicitors in Woodbridge at [email protected] on 01394 813732 or
Kerseys Solicitors in Colchester at [email protected] on 01206 584584 or
Kerseys Solicitors in Stowmarket at [email protected] on 01449 613631 or

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