Employment Rights Act: Government launches gender pay gap and menopause action plans

At a glance

• The government has published new employer guidance to support the rollout of key Employment Rights Act 2025 provisions on gender pay gap and menopause action plans.
• From April 2026, large employers (250+ employees) will be encouraged to publish actions they are taking to address their gender pay gap and support employees experiencing menopause; these plans will become mandatory in spring 2027.
• Employers must select at least one action for each area, with guidance encouraging more ambitious measures and senior leadership involvement.
• Gender pay gap action plans must be published on the government website and build on existing mandatory pay gap reporting duties.
• Menopause action plans must include at least one measure and take into account intersectional needs and workforce demographics.

The government has taken another step forward in implementing key provisions of the Employment Rights Act 2025 with the publication of employer guidance on creating action plans for both gender pay gaps and the menopause.

From April 2026, large employers with 250 or more employees will be encouraged to publish the steps that they are taking to reduce their gender pay gap. In addition, employers are encouraged to publish information on how they are supporting employees through menopause. In spring 2027, these action plans will become mandatory for large employers. Secondary legislation will be required to bring this into effect. Smaller employers are also encouraged to comply if possible.

The guidance urges employers to get senior leadership buy-in to the action plans, and suggests that training on the selected actions should be considered.

Gender pay gap action plans

Since 2017, large employers have been required to publish their gender pay gap data annually, both on their own website and also on a publicly available government website. The Equality and Human Rights Commission has been active in enforcing the publication of this data and naming businesses which fail to comply.

Until now, however, while employers have been able to include a narrative alongside their data, there has been no legal obligation to do so, nor to take any steps to reduce any gender pay gaps which exist. This will now change. Employers will have to choose at least one action to address their gender pay gap, with recommendations on a designated list to assist them. However, employers are encouraged to go beyond this and select more actions where possible.

Employers will also be able to highlight any work they are already doing to improve workplace gender equality. The plans will have to be published on the government website.

Menopause action plans

To date, employers have had no specific obligations to support employees through the menopause and protections for employees have rested on an employee relying on one of the protected characteristics under the Equality Act 2010.

Now, employers will have to choose at least one action to support employees going through the menopause. This specifically includes perimenopause. Again employers are encouraged to be ambitious and demonstrate their commitment to workplace gender equality by going further than this.

The guidance advises that menopause support should account for the fact that women with additional health conditions, or those from different backgrounds, may navigate symptoms and workplace adjustments differently. The guidance also says that employers should consider that actions may affect different groups of employees in different roles in their organisation. Where possible, employers are advised to use data on the demographics of their workforce to help choose actions that will be relevant for their organisation.

More detailed guidance for both action plans will be available in April 2026. Employers can sign up via a link in this initial guidance to be alerted when the fuller information is available. The more detailed guidance will cover:

• Understanding the issues in the employer’s organisation.
• Selecting the employer’s actions.
• Submitting the employer’s action plan.
• Tracking the outcomes of the employer’s actions.
• Reviewing the employer’s plan.

Useful links

Employment Rights Act 2025 Factsheet: Equality Action Plans

Other articles in our Employment Rights Act 2025 series

• Employment Rights Act 2025: Consultations on the trigger for collective redundancy consultation and detriments for taking industrial action - DLA Piper GENIE
• First major Employment Rights Act measures come into force - DLA Piper GENIE
• Consultations on implementation of the Employment Rights Act 2025: Flexible working, fire and rehire and tipping - DLA Piper GENIE
• Revised timeline for implementation of the Employment Rights Act 2025 - DLA Piper GENIE
• Employment Rights Bill receives Royal Assent, becoming the Employment Rights Act 2025 - DLA Piper GENIE