From 2027, larger employers will be required to go beyond gender pay gap reporting and publish detailed equality action plans to show how they are improving gender equality in the workplace.

What is the current situation?

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

There is no legal requirement to produce an action plan, although many organisations choose to create one voluntarily.

What’s changing and when?

From 2027, the Employment Rights Bill will require employers with 250 or more staff to produce and publish equality action plans, setting out specific measures being taken to address prescribed gender equality issues. This will include:

• Explaining what action the employer is taking to reduce its gender pay gap.
• Detailing how the employer is supporting employees during the menopause.

Regulations will confirm how frequently equality action plans must be published.

In addition, employers will be required to name the providers of outsourced workers in their gender pay gap reports. The start date for this requirement is yet to be confirmed.

(The Government also intends to introduce ethnicity and disability pay gap reporting for large employers through a separate Equality (Race and Disability) Bill.)

Consultations are expected on all these measures before implementation.

What you need to do now

• Assess whether your organisation is likely to have 250 or more employees by 2027 and will therefore be subject to the new rules. Even if you are below the threshold, you may wish to introduce an equality action plan as good practice.
• Review your gender pay gap data by analysing recruitment, promotion, and pay trends.
• Evaluate any existing gender pay gap action plan. Update and strengthen it where necessary. If you do not have one, start identifying actions you are taking to improve gender equality and gather evidence to support these steps.
• Plan for the impact of naming outsourced worker providers in your gender pay gap reports. Consider your providers’ own gender pay gaps and how they could affect procurement decisions. If you are a provider yourself, assess how your gender pay gap figures might influence contract opportunities.
• Review your menopause policy and action plan. Provide or refresh menopause awareness training for managers and employees, and consider whether further measures are needed to support staff experiencing menopause.

How Bhayani Law can help you

Whether you are already working with us or seeking our support for the first time, we can help you prepare for these changes and ensure your policies, reporting, and workforce initiatives are legally compliant and effective.

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.