Gender pay gap and menopause action plans: what UK employers need to know

The government has published new guidance to help employers take practical steps to support women at work. Announced on 4 March 2026 by the minister for women and equalities, Bridget Phillipson, this marks a significant moment for workplace equality and one that employers should start preparing for now.

What has been announced?

From April 2026, employers with 250 or more employees can voluntarily publish an action plan alongside their gender pay gap data. These plans will set out the steps the organisation is taking to reduce its gender pay gap and support employees going through the menopause. While currently voluntary, action plans will become a legal requirement from spring 2027 under the Employment Rights Act 2025.

The government has also published a list of 18 recommended, evidence-based actions that employers should be considering for their business, grouped into five categories: recruiting staff, developing and promoting staff, building diversity into the organisation, increasing transparency and supporting women with health conditions and menopause. Employers must select at least one action from the menopause category and at least one from the gender pay gap categories but are strongly encouraged to do more.

Why does this matter?

The gender pay gap remains a real issue driven by unpaid caring responsibilities, differences in working patterns, and the sectors women work in. The menopause is also having a tangible impact on it, with one in 10 women having left a job because of menopause-related symptoms, and a consequential loss of experience from the workplace.

There is also a growing legal risk for employers to consider: while menopause is not itself a protected characteristic, it is increasingly being raised in employment tribunal proceedings, with employees bringing sex discrimination, disability discrimination and failure to make reasonable adjustments claims. Employers who fail to take meaningful steps to support employees through the menopause face increasing legal exposure, as well as grievances and other employee relations challenges.

The guidance also emphasises that employers should look beyond gender in isolation and consider how employees may be disadvantaged in the workplace due to the overlapping impact of their sex with other characteristics such as socio-economic background, disability status and ethnicity.

What do employers need to do?

The guidance on creating an action plan sets out a clear process for employers to follow. There are five key areas for them to focus on:

• Understand the issues in the organisation. Begin by analysing the gender pay gap data to identify where the gaps are and what is driving them. Engage with employees to better understand their experiences and the specific challenges within the organisation. Use workforce demographic data where available to build a clear picture.
• Select the actions. Using the evidence gathered, businesses should choose the actions from the government's list that are most relevant to their organisation. They will also need to provide a supporting narrative explaining why they have chosen each action and what they hope to achieve. Aim to go beyond the minimum of one action in each area.
• Get the right people involved. Senior leaders must sign off the plan and commit the necessary resources. Line managers need to feel confident supporting their teams on these issues. Employees, unions and HR teams should all have a voice in shaping the plan. Organisation-wide buy-in is essential for the plan to succeed.
• Track and measure progress. Once the actions are in place, employers should put steps in place to monitor whether they are working. Further guidance on tracking outcomes will be published in April 2026 on the gender pay gap reporting service. Collecting and reviewing data regularly will help businesses demonstrate progress and refine their approach over time.
• Review and report. Action plans will need to be submitted and published on the gender pay gap service. Organisations may also publish them on their own websites. The voluntary year runs until spring 2027, giving them time to test their approach before mandatory reporting begins.

Osborne Clarke comment

While the requirements are only voluntary at present, employers should use the opportunity to get ahead before the legal obligation to produce an action plan becomes mandatory from 2027; further regulations are expected setting out the details, including the precise implementation date.

Employers should remember that the new action plan requirements sit alongside, but do not replace, existing obligations, including discrimination under the Equality Act 2010, health and safety requirements and the statutory duties in relation to flexible working requests (which themselves are subject to current reform). As well as reducing legal risk, a forward-thinking strategy (properly implemented and regularly reviewed and updated) will also help attract and retain talent, improve workplace culture, and deliver real business benefits.