UK equality action plans: what you need to know

It has been almost a decade since large employers were required to report on their gender pay gap. Legally, very little has changed since the first reporting year in 2017/2018, but in practice the dial has shifted significantly. Employers are more experienced with data collection and managing the narrative, and some have even added other protected characteristics on a voluntary basis.

But today the DE&I landscape is unrecognisable.

The shifting landscape

Back in the first reporting years 2017/18, the term “woke” had favourable connotations, and employers proudly flaunted their initiatives alongside their gender pay gap report. The UK median gap for all employers was 18.1%, so the scale of the challenge was evident. Although the UK gap has narrowed to under 13% for the April 2025 reporting year, being “woke” has transformed into an accusation rather than an aspiration, and many employers have re-thought or stripped back their initiatives and actions for fear of being accused of overreach.

Does this matter?

Yes, it matters, and for two reasons.

First, the rules are changing. From Spring 2027, employers will be required to publish equality action plans showing the steps being taken to reduce the gender pay gap and support employees experiencing menopause. There is the option to voluntarily produce and publish action plans during the 2026 to 2027 reporting year, giving organisations a chance to test their approach before mandatory reporting begins.

Second, and perhaps more importantly, the changed DE&I landscape means that initiatives and narratives crafted several years ago may no longer strike the right tone. Many employers have been publishing action plans on a voluntary basis for some time, but what felt appropriate in 2018 may now feel out of step, either too cautious or too strident for today’s environment.

The new requirements therefore present a timely opportunity to step back and review the whole package: your data, your initiatives, and, crucially, your narrative. Since many employers already publish action plans, the question is not whether to have one, but whether yours still reflects your organisation’s current position and values.

Beyond gender: menopause and other reporting

The menopause element is genuinely new territory. While the detail of the obligation is not yet known, employers should expect to explain what practical support is available, whether that includes flexible working arrangements, workplace adjustments, access to occupational health, or simply training for line managers to handle conversations sensitively. This will require employers to take stock of their current offering and identify any gaps.

It is also worth noting that disability and ethnicity pay gap reporting remain on the government’s agenda. While the timeline for these requirements is less certain, employers may wish to start considering their approach now. Ethnicity data in particular presents unique challenges. Unlike gender, it relies entirely on employees choosing to self-identify, and the categories people identify with are varied and personal. Many employers struggle with low disclosure rates, and building the trust needed for employees to share this information takes time. Starting that groundwork early will be valuable if and when mandatory reporting arrives.

Who reads pay gap reports?

Anyone and everyone. Your reports will be of interest to current employees as well as candidates vetting potential employers of choice. Shareholders, investors conducting ESG due diligence, regulators, the press, unions looking for a way into non-unionised workplaces, employee representative bodies, customers and clients with their own supply chain obligations, activist groups and campaign organisations, competitors benchmarking their own performance, and lawyers pursuing or defending a claim.

Your narrative and action plans will need to speak to this wide audience, and that is no small task. These stakeholders have very different, sometimes competing, interests and expectations. Employees and candidates may want to see ambitious commitments and tangible progress, while lawyers will be alert to anything that could be used against you in litigation. Investors and clients may expect robust ESG credentials, yet in the current climate being perceived as overly progressive carries its own reputational risks. Unions may scrutinise your plans for evidence of genuine engagement, while shareholders focus on whether initiatives represent good value. Striking the right balance will require careful drafting and a nuanced tone, one that demonstrates meaningful commitment without overreaching or creating unintended hostages to fortune.

What to do now

• Audit your current gender pay gap data and identify the key drivers behind your figures.
• Review any existing voluntary initiatives to ensure they remain aligned with business objectives.
• Consider whether to publish a voluntary action plan in 2026/27 as a dry run before mandatory reporting begins.
• Assess your menopause support offering and identify any gaps that will need addressing before the new requirements take effect.
• Brief senior stakeholders on the incoming changes and agree your organisation’s narrative approach.

We’ll keep you posted as further guidance emerges.
 

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