Equality Action Plans: What Employers Need To Know

In 2027 it will become compulsory for employers with 250 or more employees to produce and publish gender Equality Action Plans. While we await the detail of the relevant implementation legislation ahead of Spring 2027, we do not anticipate significant changes from the current voluntary regime.

This article sets out the key points employers need to be aware of to comply.

What are Equality Action Plans?

The purpose of Equality Action Plans is to support employers to take effective action to improve workplace gender equality. Equality Action Plans will show the steps an employer is taking to address any potential gender pay gap and support employees experiencing menopause.

An employer is required to set out a minimum of two actions at any one time.

Equality Action Plans will be published and available to the public, along with an organisation’s gender pay gap data.

Are Equality Action Plans compulsory?

Employers with 250 or more employees will need to produce and publish Equality Action Plans from Spring 2027 (subject to the relevant implementation legislation). Broadly speaking, employers who are already caught by gender pay reporting requirements will also be caught by the Equality Action Plan requirements. Until then, employers may voluntarily produce and publish Equality Action Plans.

My organisation needs to produce and publish an Equality Action Plan. Where do I start?

The Equality Action Plan must always set out at least two actions that are being actively worked on by the employer at any one time.

1. One action targeting the gender pay gap; and
2. One action targeting support for employees experiencing menopause.

Each active action should be classified as either ‘new’ or ‘in progress’. The third status category is ‘embedded’.

Once an action is updated to ‘embedded’, another action should be added to the Equality Action Plan so that there are always two ‘new’ or ‘in progress’ actions.

Employers can also record any pre-existing actions that are already ‘embedded’ as an established part of the organisation’s working practice.

Each Equality Action Plan requires:

• 200 words of supporting narrative on the employer’s overall action plan;
• 100 words for each action, explaining why the employer chose it and how the employer will track progress.

How do employers choose their actions?

The government has developed a list of 18 evidence-based actions for employers to choose from. The actions fall under the broad headings of:

1. Recruiting staff;
2. Developing and promoting staff;
3. Building diversity into an organisation;
4. Increasing transparency; and
5. Supporting employees experiencing menopause.

The government guidance on the 18 actions can be found here.

When deciding which actions to select from the list, employers should review any internal data to identify which actions will have the greatest impact. The selected action does not need to impact every employee in the organisation. It is advisable for organisations to discuss the actions with established stakeholder groups such as internal staff networks/groups and HR and people teams.

How do employers submit the Equality Action Plan?

Employers can create, submit and publish Equality Action Plans on the gender pay gap service alongside gender pay gap data.

Employers in the private and voluntary sectors must nominate a ‘responsible person’ to approve the Equality Action Plan. The responsible person will usually be a director, partner or senior officer. They will be responsible for confirming the information submitted is accurate.

How often do employers need to review their Equality Action Plan?

Subject to the relevant implementation legislation, employers will need to do an interim progress review after one year and again after two years of submitting the Equality Action Plan. After three years, employers will need to carry out a more detailed review. Employers should monitor the progress of their actions throughout, so that they can report their findings and what action has been taken at each review stage.