Most employers will not fail their first equality action plan because they ignored it. They will struggle because they treated it like a policy refresh, not a plan with owners, dates and evidence.
Under the Employment Rights Act 2025, large UK employers are expected to publish an action plan alongside their gender pay gap reporting. As of October 2026, government guidance says publication is voluntary now and is due to become mandatory from spring 2027, subject to legislation. That gives HR teams a window to practise. The mistakes below are the ones that tend to waste it. Check the official GOV.UK guidance before you finalise anything, because details and dates may be confirmed or changed.
What the Plan Is, in Plain Terms
The requirement applies to employers with 250 or more employees, mirroring the existing gender pay gap reporting threshold. At a minimum, the plan must set out at least one action aimed at reducing the gender pay gap and at least one action supporting employees experiencing menopause, which the guidance describes as including perimenopause and post-menopause. The plan is published through the government's gender pay gap reporting service. The guidance encourages employers to go beyond the two minimum actions and to track progress against the actions they choose.
That is a short description of a requirement that is easy to underestimate. Two actions on paper are simple. Two actions that survive scrutiny from staff, candidates and the public are harder.
Mistake 1: Assuming Scope Without Checking Headcount
If you have 250 or more employees, you are in scope. If you are just below the threshold, you may still be asked about menopause support by staff, by customers' procurement teams or by prospective hires. Smaller employers already have duties under the Equality Act 2010 around sex, age and disability, and menopause symptoms can in some circumstances engage those protections. The plan is a useful template even if you are not yet required to publish one.
Mistake 2: Writing Actions Nobody Owns
An action such as "we will support employees going through menopause" is a sentiment, not an action. A workable action has an owner, a start date, a measure and a review point. Compare the two:
- Vague: improve awareness of menopause across the business.
- Specific: brief all line managers on a written menopause adjustments process, name the HR lead responsible, and review how many requests were handled and how quickly after six months.
The specific version can be checked by someone who was not in the room when it was written, which is the standard to aim for.
Mistake 3: Copying Another Employer's Plan
Published plans from other organisations are useful for seeing the format. They are a poor guide to what your workforce needs. A warehouse with shift patterns and a mostly desk-based professional services firm will have different practical barriers, from temperature and uniform to flexible working and sickness absence handling. Start from your own data: gender pay gap figures, absence patterns, exit interview themes and anything staff have told you through surveys or networks.
Mistake 4: Leaving Staff Out of the Process
The guidance I reviewed does not set out a formal consultation step, but there is a practical reason to ask people anyway. Actions designed without input from the people affected tend to miss the real obstacles, and they are the ones most likely to notice if the plan is not delivered. A short anonymous survey, a conversation with an employee network or a session with line managers can reshape an action before it is published.
Mistake 5: Treating Menopause as Only an HR Wellbeing Topic
Menopause support sits across several areas at once. Line managers need to know how to respond to a conversation. Occupational health may need a role. Absence and performance procedures need to be checked so that menopause-related symptoms are not handled as capability problems by default. Facilities, uniform and working environment can matter. If the plan sits only inside a wellbeing programme, the policies that actually shape someone's day may stay unchanged.
Mistake 6: Waiting for Enforcement Detail Before Doing Anything
The sources I checked do not set out specific penalties for the plan itself, and the secondary legislation that confirms the mandatory start has yet to arrive. It is reasonable to want certainty. It is also a risk to assume that no detail means no consequence. Published plans are public, and reputational scrutiny from employees, applicants and the press is a realistic pressure on its own. Separately, failing to handle a menopause-related issue properly can lead to discrimination or unfair treatment claims under existing law, whatever the plan says.
A Sensible Order of Work
- Confirm whether you are in scope and when your reporting date falls.
- Gather the data you already hold: pay gap results, absence, turnover and survey responses.
- Choose at least one pay gap action and one menopause action, then test each against the owner, date and measure checklist.
- Ask staff and managers what would make the actions useful in practice.
- Decide how you will track progress and who reports it internally.
- Treat the 2026 to 2027 period as practice, then refine before the plan becomes mandatory.
Frequently Asked Questions
Is the action plan mandatory now?
As of October 2026, government guidance describes publication as voluntary, with the requirement due to become mandatory from spring 2027 subject to legislation. Check GOV.UK for the current position.
Which employers are covered?
Employers with 250 or more employees, in line with gender pay gap reporting.
What is the minimum content?
At least one action to reduce the gender pay gap and at least one action supporting employees experiencing menopause.
Do we have to cover conditions such as endometriosis?
One law firm summary of the guidance says employers may choose to extend support to related conditions but are not required to. Confirm against the official guidance.
Where is the plan published?
Through the government's gender pay gap reporting service, alongside your reporting.
Where to Go From Here
If you want a structured route through the new regime rather than a blank page, Menopause & Equality Action Plan Compliance is written for UK employers and HR directors preparing for the Equality Action Plan requirements under the Employment Rights Act 2025. Its product description frames the challenge as one many employers are not yet ready for, and it is aimed at helping you prepare before getting it wrong becomes costly.
It is an independent guide, so it works best alongside the official GOV.UK guidance and your own legal or HR advice, not in place of them.
Get Menopause & Equality Action Plan Compliance →
This article is general information only and is not legal, tax, financial or medical advice. Requirements and dates may change, so check current official guidance on GOV.UK. The product mentioned is an independent guide and is not produced or endorsed by the UK government.