Equality Action Plans: What employers need to know
From April 2026, large UK employers can publish an Equality Action Plan alongside their gender pay gap data, and from 2027 most will have to. Here's what has to go in one, where the menopause requirement sits legally, and how to choose actions that fit your workforce.
What's changing, and when it becomes mandatory
Employers with 250 or more staff can now publish an Equality Action Plan alongside their gender pay gap data on the government's reporting service, and the government intends to make this compulsory from spring 2027, subject to secondary legislation.
For 2026, publishing a plan is voluntary. That gives employers a genuine run at getting the format and the substance right before it becomes a requirement, rather than scrambling to produce something credible under a legal deadline. The Office for Equality and Opportunity has published detailed guidance and a list of recommended actions to help with that, alongside the existing gender pay gap reporting rules.
What your plan actually has to include
The guidance requires at least one action addressing your gender pay gap and at least one addressing menopause support, with organisations encouraged to go further where it makes sense for their workforce.
Beyond those two minimums, the government's list of recommended actions falls into five areas: recruiting staff, developing and promoting staff, building diversity into the organisation, increasing transparency, and supporting employees experiencing menopause. Employers can also use the plan to describe work already under way, rather than starting from nothing.
Where menopause sits, legally
Menopause itself is not a protected characteristic under the Equality Act. Severe symptoms can qualify as a disability where they have a substantial, long-term effect on daily life, and where that threshold is met, employers may need to make reasonable adjustments.
Employment tribunal cases involving menopause have risen in recent years, often centred on discrimination or a failure to make adjustments. A menopause action or two is not simply a box to tick for the 2027 deadline. It is increasingly a live area of employment risk in its own right, deadline aside.
Choosing actions that fit your workforce, not just the list
The government's recommended actions span recruitment, career progression, transparency and representation, and the point of the plan is to select what is actually relevant to your organisation rather than working through the list top to bottom.
A business with a strong graduate pipeline but few women reaching senior roles has a different problem to one struggling to attract applicants in the first place, and the plan should read that way. The guidance also encourages employers to think about how experience differs by ethnicity, disability and socioeconomic background, even though there is no requirement to measure or report on this separately. Employers who engage with that seriously, rather than as an afterthought, tend to produce plans that hold up to scrutiny once reporting becomes mandatory.
What you can do now
Read the government's list of recommended actions and mark which ones already reflect something your organisation does, so your plan starts from an honest baseline rather than a blank page.
Choose your gender pay gap action and your menopause action based on where your own data and staff feedback point, not the actions that are easiest to write about.
If you have not yet reviewed how menopause symptoms could interact with your disability and reasonable adjustment policies, do that before you publish, since tribunal exposure does not wait for the 2027 deadline.
Frequently asked questions
When do Equality Action Plans become mandatory?
From spring 2027, subject to secondary legislation. Publishing one is voluntary for 2026.
Which employers need to publish an Equality Action Plan?
Currently, employers with 250 or more employees, in line with existing gender pay gap reporting thresholds.
What has to be included in an Equality Action Plan?
At least one action addressing the gender pay gap and at least one addressing menopause support, drawn from the government's recommended list or an employer's own initiatives.
Is menopause a protected characteristic under the Equality Act?
No, but severe symptoms can meet the legal test for disability, which can bring a duty to make reasonable adjustments.
This post is for informational purposes only and does not constitute financial, legal or HR advice. For guidance specific to your organisation, speak to an employment law specialist.