What is the current situation?

Employers with 250 or more employees are currently required to publish an annual gender pay gap report. This must show the average and median pay differences between male and female employees.

At present, there is no legal requirement to publish a gender pay gap action plan, although many employers choose to do so on a voluntary basis.

So what’s changing and when?

Employers with 250 or more employees will be required to develop and publish equality action plans, setting out the steps they are taking in relation to certain prescribed gender equality issues. This will include explaining:

• What action is being taken to address the organisation’s gender pay gap; and

• How the employer is supporting workers experiencing the menopause.

These measures are expected to be introduced on a voluntary basis from April 2026, before becoming mandatory in 2027.

Further regulations will set out the detailed requirements, including how often equality action plans must be published.

In addition, regulations will require employers to name any providers they engage for outsourced workers within their gender pay gap reports. The implementation date for this requirement has not yet been confirmed.

Separately, the Government has indicated that it plans to introduce ethnicity and disability pay gap reporting for large employers through a future Equality (Race and Disability) Bill.

What you need to do

If you are likely to employ 250 or more employees in 2027, you should start considering the following steps now. Even if you do not expect to reach this threshold, you may wish to consider whether developing an equality action plan would be good practice for your organisation.

• • Review your gender pay gap data, including recruitment, promotion and pay patterns.

  • Consider whether you already have a gender pay gap action plan in place. Does it need updating or strengthening? What steps are you taking to improve gender equality, and what evidence supports those actions?

  • Think about the implications of naming providers of outsourced workers in your gender pay gap report. What are their gender pay gap figures? If you are a provider yourself, how might your own data impact your ability to win or retain contracts?

  • Review whether you have a menopause policy and/or menopause action plan in place. If so, has it been reviewed recently? Consider whether managers and the wider workforce would benefit from menopause awareness training, refresher sessions, or additional support measures for workers going through the menopause.

How Bhayani Law can help you

Bhayani Law can support you to review your gender pay gap data and develop a clear, practical equality action plan aligned with upcoming legal requirements. We also advise on menopause policies, workforce training, and the implications of outsourcing arrangements, helping you prepare confidently for the 2026–2027 changes.

Already working with Bhayani Law?

You will receive updates on legal developments, ensuring you remain compliant and informed.

We offer detailed HR and employment law resources, including template policies and letters on our Watertight HR Hub.

If you need advice, your dedicated advisor can assist with policy reviews, drafting, and updates.

Our HR and legal team can also deliver menopause awareness training for managers and teams, conduct diversity audits, carry out pay gap analysis, help design effective action plans, and provide unconscious bias training to improve recruitment and retention practices.

New to Bhayani Law?

You don’t need to navigate these changes alone. Whether you need short-term input or long-term HR and legal support, we offer tailored solutions to fit your organisation’s needs.