The UK government has announced new employer action plans designed to strengthen the existing gender pay gap reporting framework. The initiative forms part of the wider employment reforms linked to the Employment Rights Act 2025 and the government’s “Make Work Pay” programme.
While the current system focuses on publishing pay data, the new framework is expected to place greater emphasis on explaining why gaps exist and what organisations are doing to address them.
Alongside pay gap analysis, the government has also confirmed that menopause support will form part of the expected workplace measures within these plans. For many HR functions, this will bring menopause policy and training into the core equality and workforce management agenda.
How the current gender pay gap system works
Under the existing regulations introduced under the Equality Act 2010, employers with 250 or more employees are required to publish gender pay gap data each year.
The data shows the difference in average pay between men and women across the organisation. Employers publish figures covering hourly pay gaps, bonus pay gaps, the proportion of men and women receiving bonuses and the gender distribution across pay quartiles.
Many organisations already publish a voluntary narrative explaining the figures. However, there is currently no legal requirement to explain the causes of the gap or to set out any measures to reduce it.
The proposed action plans are intended to fill that gap.
What the new equality action plans are expected to involve
Under the government’s proposal, employers with 250 or more employees will be encouraged to publish a gender equality action plan alongside their gender pay gap data. The plan will explain the factors contributing to the organisation’s pay gap and outline the steps being taken to address it.
In practice, this means HR teams will need to move beyond reporting statistics and start documenting the factors contributing to pay differences. This could involve examining issues such as gender representation across senior roles, promotion patterns, recruitment pipelines and retention trends. Organisations may also need to review reward practices, career progression pathways and the availability of flexible working.
In other words, the reporting exercise is likely to evolve into a broader workforce analysis exercise.
Menopause support moves into mainstream HR policy
One of the more notable elements of the proposal is the inclusion of menopause support within workplace equality planning.
The government has highlighted menopause as a factor that can affect workforce participation and career progression for women in mid-career. As a result, employers are expected to consider how workplace policies support employees experiencing menopause symptoms.
For HR professionals, this may involve introducing or expanding menopause policies, providing training for line managers and reviewing workplace adjustments that can support employees during this stage of working life. This might include practical measures such as flexible working arrangements, clear guidance on requesting support, or adjustments to working environments where symptoms affect comfort or concentration.
While menopause itself is not a protected characteristic under the Equality Act 2010, employment tribunals increasingly consider menopause-related issues in discrimination claims involving sex, age or disability.
That legal context explains why the issue is now moving into mainstream HR policy.
Implementation timeline
The government has indicated that the policy will be introduced in stages.
Employers are expected to be encouraged to adopt gender equality action plans from April 2026. This initial phase allows organisations to develop internal processes and gather the workforce data needed to produce meaningful plans.
The government has indicated that the voluntary phase may lead to a future compulsory reporting framework for large employers, although the final structure and timing have not yet been confirmed.
Detailed regulations will confirm the final reporting format once the legislation is published.
What HR teams should be preparing for
Although the formal reporting duty has not yet taken effect, the direction of policy is clear. Gender pay gap reporting is moving toward a system where organisations explain the causes of pay differences and show what action they are taking.
For HR teams, preparation will likely involve strengthening the internal analysis behind pay gap reporting and building clearer links between workforce data and equality initiatives.
This may include reviewing promotion and recruitment patterns, assessing gender representation across senior roles and examining whether workplace policies support retention at different stages of employees’ careers.
Many organisations are also beginning to formalise menopause support policies and training programmes as part of wider wellbeing and equality strategies.
The practical effect is that gender pay gap reporting is evolving from a once-a-year reporting exercise into a more continuous HR governance issue, involving workforce analysis, policy development and leadership accountability.
Further detail on the legal framework will be published when the government introduces the regulations implementing the new reporting requirements.
Author
Gill Laing is a qualified Legal Researcher & Analyst with niche specialisms in Law, Tax, Human Resources, Immigration & Employment Law.
Gill is a Multiple Business Owner and the Managing Director of Prof Services - a Marketing & Content Agency for the Professional Services Sector.
