Larger employers will need to develop and publish reports on their plans to improve gender equality

What is the current situation?

Employers with 250 or more employees must publish an annual gender pay gap report that shows the average and median pay differences between male and female employees.

There is currently no legal requirement to publish an action plan, although many employers choose to do so voluntarily.

So what’s changing and when?

Employers with 250 or more employees will be required to develop and publish equality action plans showing what steps they are taking in relation to certain prescribed gender equality matters. This will include explaining what action the employer is taking in respect of its gender pay gap and how it is supporting workers during the menopause. These measures are expected to be introduced on a voluntary basis in April 2026, before coming into force in 2027. The Government also plans to publish menopause guidance in April 2026.

Regulations will set out the detailed requirements and provide how often employers will need to publish their equality action plans. 

In addition, regulations will require employers to name the providers they contract with for outsourced workers in their gender pay gap reports. The implementation date for this has not yet been indicated. 

(The Government separately plans to include ethnicity and disability pay gap reporting obligations for large employers in a new Equality (Race and Disability) Bill. A Government consultation on mandatory ethnicity and disability pay gap reporting closed on 10 June 2025, and we are awaiting the Government’s response.)

What you need to do

If you are likely to have 250 or more employees in 2027, you should consider taking the steps below. If you are unlikely to meet the 250 employees threshold in 2027, consider whether, as a matter of good practice, you wish to develop an equality action plan in any event.

• Review your gender pay gap data by examining recruitment, promotion and pay information.
   
• Consider any gender pay gap action plan you already have in place. Does it need updating? Can it be improved? What are you doing to improve gender equality, which you could include in an action plan, and what evidence are your actions based on?
   
• Consider the impact of naming providers of outsourced workers in your gender pay gap report. What is the gender pay gap of your providers? If you yourself are a provider, how might your own gender pay gap figures affect your ability to gain or retain contracts? 
   
• Do you have a menopause policy and/or a menopause action plan? If so, have you reviewed them recently? Consider whether your managers and wider workforce would benefit from menopause awareness training or a refresher course. Are there any additional measures you could take to support 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.