What to include in gender pay gap action plans
In the UK, there is an average gender pay gap of around 13%, and at the current rate of progress, it is estimated to take between 40 and 45 years to close the gender pay gap in the UK, with some projections stretching to 2065.
While the requirement for companies with 250 or more employees to publicly publish their gender pay gap data has been in place since 2017, the Employment Rights Act 2025 brings a significant shift in expectations for employers.
From this month, gender pay gap action plans became voluntary, but mandatory by Spring 2027 for companies with 250 or more employees.
These new measures in the Employment Rights Act offer a chance to address inequities head on, and while there is still more to be done, this is a positive step in the right direction.
What is a gender pay gap action plan?
A gender pay gap action plan is a written framework that clearly sets out how an organisation will aim to improve the gender pay gap.
A gender pay gap action plan ensures active accountability. With 68% of women saying their career has stalled as a result of having a child and 1 in 10 women leaving work due to menopause symptoms (often at the peak of their careers), the plans will normalise transparency and support for life stages that have historically been sidelined, particularly when it comes to starting a family and menopause.
The gender pay gap action plan needs to be signed by the most senior employee and published on a public facing website as well as the government's gender pay reporting website.
What HR and People teams need to do
For HR managers and leadership teams, the time to prepare action plans grounded in practical strategies is now.
Any plan needs to include at least one action that is specifically related to how the organisation will tackle the gender pay gap, rather than just the data itself.
When thinking about an action plan, first identify the root cause of any gender pay gaps in the organisation.
No-one can fix a gap they don’t acknowledge or understand. Are women missing from senior leadership roles? Is there a lack of support for those returning from maternity leave?Companies should use data to pinpoint exactly where any disparities lie.
Next, identify at least one action to combat the gender pay gap. Of course, while one is the legal minimum, companies can absolutely implement more and at Fertifa, this is something we strongly encourage.
Some examples of practical strategies a gender pay gap action plan could include:
Recruitment
- Make sure job descriptions are inclusive and use neutral language, so all individuals feel welcome and able to apply
- Encourage applications from candidates of all backgrounds, actively targeting outreach to people who might find it more difficult to apply
- Use a structured skill-based screening to remove unconscious bias when reviewing CVs and whilst interviewing
- Offer a flexible interview process by default, making it easy for people to interview for the role remotely (this is especially helpful if they have caregiver responsibilities)
Promotion
- Automatically consider all eligible employees for a promotion, including those on parental leave, rather than having employees opt in for promotions
- Provide mentoring or sponsorship so employees have a formal route to access advice and support for long-term career development
- Ensure all employees receive ongoing, clear feedback and advice on their progression
Prioritise diversity
- If there isn’t a dedicated DEI team, consider hiring a diversity manager or lead within the organisation who will hold senior leaders and hiring managers to account for recruitment and promotion decisions
- Keep in mind that gender pay gaps are not uniform and larger gaps often exist for minorities
- Set specific time-based targets that aim to improve gender pay gap and specifically aimed at improving gender representation throughout all levels of the organisation
Pay and promotion transparency
- Ensure promotion criteria are written down and accessible to all staff, to help individuals understand how decisions are made and when they can ask for a promotion or pay increase
- Make sure pay and salary ranges are visible and accessible to all employees as the gap is often a by-product of reward architecture
Provide meaningful support for female employees with clinically-led healthcare
- Offer female employees support that adds value to their lives by working with a provider such as Fertifa, that fills critical healthcare gaps in PMI provision
- Supporting employees through pivotal life moments such as trying to conceive, pregnancy and postpartum, returning to work and infant care, women’s reproductive health and menopause has a direct impact on retention and the gender pay gap
- Provide enhanced and equal maternity and paternity pay as an equaliser
- Fertifa provides employees with fast and easy access to specialist doctors, nurses, and midwives, for all women’s health and gynecological challenges
Integrating menopause support as part of your menopause action plan
In addition to gender pay gap action plan, employers with more than 250 employees will also be required to implement a menopause action plan from 2027. This must include at least one specific action regarding support for menopause.
Today, 8 in 10 women report a lack of support for menopause in their workplace.
Addressing this is a critical component of retaining senior female talent in leadership positions, consequently helping companies reduce the gender pay gap at senior levels.
The value of early action
Whilst gender pay gap action plans are not mandatory until 2027, to make a meaningful difference, early action is always the best course and many organisations are choosing to implement these plans voluntarily.
Taking steps now will ensure employees are supported at an earlier stage and it will also help avoid a rush when the regulations become compulsory. Boards, investors, current employees, and future talent are increasingly looking at how organisations are addressing these issues. Being proactive reflects leadership and a genuine commitment to inclusion.
To help navigate more of the employment law changes taking place in 2026 and 2027, we've created a useful downloadable calendar.
Supplied by REBA Associate Member, Fertifa
Leading health benefits provider, offering best-in-class clinical care for neurodiversity and reproductive health.
