Employment Rights Act 2025: equality action plans
Ahead of International Women’s Day 2026, the Government took another step forward in their implementation of the Employment Rights Act 2025 by introducing equality action plans for gender pay reporting and menopause support. Launched on 4 March 2026 by Bridget Phllipson, the Minister for Women and Equalities with the aim of supporting women to succeed at work, these action plans require employers to detail steps they are taking to address any pay disparities associated with gender and support they are providing to menopausal women in the workplace.
Gender pay reporting
Compulsory gender pay reporting for employers with 250 or more employees was introduced in April 2017 however to date, there has been no requirement for employers to publish any commentary which sits alongside this. The proposal is that from April 2027, it will become mandatory for employers to publish an action plan alongside their gender pay gap data to document what steps they are taking to address any noted issues, with employers being actively encouraged to produce such a plan on a voluntary basis from this April. These action plans will be published on the gender pay gap portal which is already in place and employers with under 250 employees also being encouraged to participate in the process on a voluntary basis.
Some employers already publish action plans but the announcements will mean that employers should review existing action plans with renewed vigour, or be ready to produce one. Producing an action plan on a voluntary basis from this April will allow employers to trial their mechanisms for change and have data ready by next year, in which to inform the mandatory plan.
Menopause
Whilst gender pay gap reporting has been around for almost a decade, the announcement of the requirement to produce a menopause action plan represents a step forward in Governmental policy given it is the first requirement of this kind. It feeds into wider Government policy on diversity, equality and inclusion given that there are already proposals in place to introduce requirements for employers to report on disability and ethnicity pay gaps. Further information is needed on the production of this plan but the Government notes that a plan of this sort may also support employees experiencing other health conditions related to menstrual health such as endometriosis, fibroids or polycystic ovarian syndrome.
The news of this announcement has been welcomed by many and heralded as a first step of transforming what some employers have already implemented as a good practice measure, into a clear legal requirement.
Employer guidance
Employer guidance, published as part of these proposals describes that the purpose of the action plans will be to support employers to take effective action to improved workplace gender equality and lists a number of recommended evidence-informed actions that employers can use in their plans.
These actions fall under five categories, each with its own guidance:
1. Recruitment staff
| Guidance note | Example of recommendations |
|---|---|
| Making job descriptions inclusive | Develop neutral job titles and avoid terms associated with male stereotypes such as ‘competitive’ and ‘dominant’. |
| Encourage applications from a range of candidates | Asking managers to email applicants who just missed out on a role to encourage them to apply for other jobs or offering paid “returnships” to offer extra support for people coming back to the workplace. |
| Reduce unconscious bias in CV screening | Review and adjust the outputs of Artificial Intelligence (AI) where AI is used to assist with CV screening to avoid the AI learning and repeating any learned gender biases. |
| Use fair and structured interview techniques | Set up recruitment panels which include both men, women and a mix of ethnic groups and decide on benchmark data for interview questions before starting interviews. |
| Advertise leave policies in job adverts | Use a dedicated section in the job advert to explain the types of leave you offer including listing any eligibility rules for these. |
| Advertise flexible working arrangements in job adverts | Give specific examples of arrangements that work for the role being advertised and sharing examples of colleagues who work flexible, especially those in senior roles. |
2. Developing and promoting staff
| Guidance note | Example of recommendations |
|---|---|
| Automatically consider eligible employees for promotion | Allowing staff to opt-out of promotion process rather than opt-in. |
| Encourage employee development through actionable steps | Training mangers on how to give effective and actionable feedback and encouraging meetings to take place for developmental advice. |
| Offering mentoring, sponsorship and other development programmes | Using surveys to consult with employees about their development goals and any barriers in order to build and develop a relevant programme. |
3. Building diversity into your organisation
| Guidance note | Example of recommendations |
|---|---|
| Set targets to improve gender representation | Use targets to speed up on gender representation, with realistic deadlines for review and ensuring the targets are visible to stakeholders at all levels. |
4. Increasing transparency
| Guidance note | Example of recommendations |
|---|---|
| Increasing transparency for pay, promotion and rewards | Review policies and for example share decisions about pay banding or listing the criteria and processes you use to make decision for promotions or salary reviews. |
| Enhance and promote flexible working and leave policies | Publishing and promoting policies to make it easier for employees to understand and access them as well as encouraging a supportive culture such as setting up employee networks. |
5. Supporting employees experiencing menopause
| Guidance note | Example of recommendations |
|---|---|
| Train managers to support employees experiencing menopause | Evidence suggests that investing in training could increase trust, improve retention, improved the use of inclusive policies and create a culture shift. |
| Offer occupational health advice for employees experiencing menopause | Work with your occupational health provider to get expert guidance on menopause or other conditions relating to menstrual health. |
| Set up menopause support groups and networks | Research suggests that peer support, along with other workplace adjustments may help women manage their symptoms which may lead to fewer days off for menopause-related absence. |
| Offer workplace adjustments | Research has found that one in ten women who work during the menopause leave their jobs because of their symptoms. If this happens because employers do not offer enough support or flexibility then addressing this could improve retention rates. |
| Conduct a menopause risk assessment for your workplace | Risk assess your work environment to consider; the temperature and ventilation of the workplace, uniform requirements, rest and toilet facilities, the availability of cold drinking water and manager training. |
| Review policies and procedures to meet the needs of employees experience menopause | Review a suite of organisational policies but consider running confidential consultations on these and gathering feedback from those with specific needs in order to gather enough data to appropriate inform the policy reviews. |
Additional guidance for employers on creating an action plan will be published in April 2026 and from this date employers will also be encouraged to share evidence-based actions to support change processes.
Practical steps to take now
The introduction of these action plans aims to create meaningful change and carry obvious benefits for employers in terms of retention, productivity and employee engagement. It’s therefore essential that early consideration is given to these requirements and in readiness, employers can consider the following steps:
- Review any internal policies such as menopause or flexible working policies and engage your workforce on their efficacy
- Assess manager knowledge of such initiatives and consider future training requirements
- Audit gender pay gap data
- Consider your organisational values and assess whether they are aligned to the priorities in any gender pay data
Tags: Employment Rights
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