Gender pay gap and menopause action plans launched in the UK

The Government has launched gender pay gap and menopause action plans. 

From April 2026, employers with 250 or more employees will have the option of publishing a voluntary action plan. They will become mandatory from spring 2027 (subject to secondary legislation).

The purpose is to show the steps the employer is taking to: (a) reduce their gender pay gap; and (b) support employees experiencing menopause.

The Government has published guidance for employers on the plans, including a list of recommended actions to include. The actions cover: recruiting staff (eg making job descriptions inclusive and flexible working arrangements); developing and promoting staff (e.g. offering mentoring, sponsorship and other development programmes); building diversity into the organisation (e.g. setting targets to improve gender representation); increasing transparency (e.g. for pay, promotion and rewards); and supporting employees experiencing menopause (eg offering occupational health advice and setting up menopause support groups).

Employers must include at least two actions in an action plan – one each on the gender pay gap and menopause, but the guidance encourages them to be ambitious and select more where possible. It also emphasises the importance of engaging those in the organisation, including getting the 'buy-in' of senior leaders.  

Employers are encouraged to consider how employees may be disadvantaged in the workplace due to the overlapping impact of their sex and other characteristics. For example, menopause support should account for the fact that women have additional health conditions. The guidance urges employers to use data on the demographics of their workforce to help choose actions that will be relevant for their organisation.   

Further, more detailed guidance will be published in April 2026 and will cover:

1.    Understanding the issues in the employer’s organisation;

2.    Selecting the employer’s actions;

3.    Submitting the employer’s action plan;

4.    Tracking the outcomes of the employer’s actions; and

5.    Reviewing the employer’s plan.

Action plans will need to be submitted and published on the gender pay gap service. Published action plans will be available to the public along with employers' gender pay gap data. 

There do not appear to be any specific sanctions for non-compliance once these plans become mandatory, but the information (or lack thereof) will be in the public domain. As such, the plans will be scrutinised by employees (and their lawyers), unions, investors, clients and shareholders. This may put sufficient pressure on employers to drive compliance but given that not all third parties will have the same interests, employers will need to draft the plans carefully so that they balance those interests. 

This article was authored by Melissa Paz, special counsel in our UK employment team.