However, employers are being encouraged to produce GEAPs voluntarily from April 2026, with submission in April 2027.
Why are gender equality action plans needed?
Recent OECD statistics show female labour force participation has been a key driver of economic growth since 2000. This is despite figures for mandatory gender pay gap reporting in 2025 showing the median of reported mean gender pay gaps sitting at 11.2% and, according to the Fawcett Society in 2022, 1 in 10 women leaving their jobs due to their menopausal symptoms.
The new framework
The Employment Rights Act 2025 introduces a new framework for publishing gender equality action plans (GEAPs), aimed at strengthening transparency and demonstrating practical steps towards improving equality of opportunity between men and women in the workplace.
Under the new framework, larger employers will be required to publish GEAPs alongside their annual gender pay gap report. Smaller employers are also encouraged to voluntarily implement GEAPs where possible. The plans must set out the steps an organisation is taking to address its gender pay gap and to support employees experiencing menopause. The GEAPs will also provide employers with an opportunity to highlight what they are already doing to tackle workplace inequality.
Will businesses benefit from acting now?
There are several reasons for businesses to consider producing GEAPs in advance of the legal requirement to do so. Early adoption can be beneficial in preparing for future compliance. Developing a meaningful action plan will require audits of current practices, analysis of their effectiveness, consultation with stakeholders and identification of steps that may be taken to effect improvement. Starting the process now will allow larger businesses to hit the ground running when the requirement becomes binding.
Voluntary publication may also enhance reputation in what is currently a high-profile, closely monitored area of employment practices. Being seen to be ahead of the curve with a clear strategy to tackle gender inequality may enhance organisational reputation with employees, impacting both recruitment and retention, and with customers and/or investors.
What should employers be doing?
In March the UK government published overview guidance, Creating an action plan: guidance for employers, to help and encourage employers to produce GEAPs voluntarily. It has also produced a list of 18 recommended evidence-informed actions that employers can take. Businesses must include at least two actions in their first GEAP. One should relate to the gender pay gap, the other to supporting employees going through menopause. More detailed guidance covering the steps employers should take when creating their action plan, Creating an action plan: guidance for employers, was published in April. Employers should review this guidance at the start of the process of creating their GEAP.
What is next?
Regulations will be laid before Parliament in due course. The regulations may provide further details on the content of GEAPs, the form and manner of publication, frequency of publication (which will not be more than once a year) and, significantly, requirements for senior approval before publication.
While GEAPs will not be mandatory for larger employers until 2027, the policy direction is clear. Businesses that are able to develop and publish the GEAPs now will both be better positioned to meet the mandatory requirements in 2027 and be seen as leading the fight against workplace inequality.
