Equality action plans are one of the Employment Rights Act 2025 changes that sound bigger than they are, and also smaller than they turn out to be. The rule itself is short. The work of producing a plan you can stand behind is not. Here is what a plan is, who has to publish one and when, and the evidence worth keeping from the start.
What an equality action plan is
GOV.UK's guidance Creating an action plan: guidance for employers describes it as a plan published alongside your gender pay gap data on the government's gender pay gap reporting service. It must contain at least two actions:
- at least one action to address the gender pay gap, and
- at least one action to support employees experiencing menopause.
Two is the minimum, not the target. The guidance encourages employers to choose more, and it suggests metrics for each action so you can track progress. Published plans are public, sitting next to your pay gap figures for anyone to read.
Who it applies to
The threshold is 250 or more employees, the same as gender pay gap reporting. In a group, GOV.UK says each separate legal entity with 250 or more employees submits its own plan. Entities can tailor their plans or use the same actions and narrative across them.
If you employ fewer than 250 people, there is no duty to publish a plan. That does not mean menopause is off your desk. The Equality Act 2010 duties on sex, age and disability, and your health and safety duties, apply to employers of every size, and menopause symptoms can engage them. A small employer can use the same two-action structure as a sensible internal plan without publishing anything.
When: voluntary now, mandatory from spring 2027
For the 2026 to 2027 reporting year, GOV.UK says employers in scope can publish a plan voluntarily, at any point up to the reporting deadlines: 4 April 2027 for private, voluntary and most other employers, and 30 March 2027 for most public authority employers. The guidance says plans become mandatory from spring 2027, subject to legislation. Check the current GOV.UK page before you rely on a date, because the detail depends on regulations that are still to be made.
That makes this reporting year a rehearsal. A voluntary plan published now lets you find the gaps in your data and processes while nothing is compulsory.
Who signs it off
GOV.UK says private and voluntary sector employers must name a responsible person when submitting: usually a director, partner or senior officer who confirms the information is accurate. Most public authority employers do not currently need one. Whoever it is should see the evidence behind each action before they put their name to it.
A simple order of work
- Confirm scope: headcount for each legal entity, using the same approach as your gender pay gap reporting.
- Understand the issues: look at your pay gap data and talk to staff, including about menopause support, before choosing anything.
- Choose your actions: at least one pay gap action and one menopause action from the government's list, each with an owner and a date.
- Set the measures: decide how you will know each action is working, using the suggested metrics where they fit.
- Sign off and publish: brief the responsible person, then submit on the gender pay gap service.
- Review next year: report progress against the same measures, not a fresh list.
Keep the proof
Keep one file per entity with: the headcount calculation, the data and staff feedback you used, why you chose each action, the owner and deadline for each, your measures and baseline figures, the responsible person's sign-off with date, and the submission confirmation. When staff, a tribunal or the press ask what you did, the file answers.
The guide that sets this out step by step
The Menopause & Equality Action Plan Compliance Blueprint (UK Edition, for employers, HR and people teams) covers the 2025 to 2027 timeline, the 250-employee threshold and legal-entity structures, the government-recommended menopause actions, writing the plan and supporting narrative, senior sign-off, publishing, year-on-year tracking, and an Equality Action Plan preparation checklist. It also covers the existing Equality Act and health and safety duties that apply whatever your size. It is also available on Amazon in Kindle and paperback.
Explore the guide and instant PDF download.
Know what changed. Know what to do. Keep the proof.
📘 PDFBlueprints — plain-English UK compliance guides for landlords, sole traders & small employers. Checklists, trackers & templates. Instant PDF. General information, not legal advice. Threshold, minimum actions, voluntary deadlines, legal-entity and responsible-person rules checked against GOV.UK "Creating an action plan: guidance for employers" (updated 13 May 2026) on 27 October 2026.