A Jamie HR manager's guide

The manager's guide to gender pay gap reporting and equality action plans in 2027

A practical guide for managers and businesses with 250 or more employees on the existing gender pay gap reporting regime, the equality action plan duty the Employment Rights Act 2025 adds, and how the timeline to spring 2027 is shaping up.
250+ employee threshold
Equality action plans
Spring 2027

Gender pay gap reporting is about to gain a second, connected duty.

The Employment Rights Act 2025 adds a duty to publish an equality action plan on top of existing gender pay gap reporting. This guide sets out both, what is confirmed about the spring 2027 timeline, and why the separate ethnicity and disability pay gap reporting proposal is not part of this Act.

What's inside
Gender pay gap reporting today3
What the Employment Rights Act 2025 adds4
What an equality action plan must include5
The timeline: voluntary now, mandatory from 20276
What is genuinely still unsettled7
Ethnicity and disability pay gap reporting: a separate change8
Preparing your gender pay gap data now9
Getting ready for 2027: the essentials10
How Jamie HR helps11

Gender pay gap reporting today

The existing reporting regime is already well established for employers of a certain size.
  • Employers with 250 or more employees on their snapshot date must report gender pay gap data, under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.
  • Private, voluntary and most public authority employers use 5 April as their snapshot date; most public authority employers use 31 March.
  • Six figures must be published: the mean and median gender pay gap in hourly pay, the mean and median gender pay gap in bonus pay, the percentage of men and women receiving a bonus, and the percentage of men and women in each hourly pay quarter.
  • Reports are submitted through the government's gender pay gap service, within 12 months of the relevant snapshot date: by 4 April for private, voluntary and other public authority employers, and by 30 March for most public authority employers.

What the Employment Rights Act 2025 adds

The Employment Rights Act 2025, which received Royal Assent on 18 December 2025, introduces a new duty on top of the existing reporting requirement.
  • Section 33 of the Act inserts a new section 78A into the Equality Act 2010, giving government the power to require employers to develop and publish an equality action plan.
  • An equality action plan is a published document setting out the steps an employer is taking on prescribed gender equality matters.
  • The matters named in the Act include addressing the gender pay gap and supporting employees through the menopause.
  • The duty is aimed at employers already required to report gender pay gap data, the same 250-or-more-employee threshold as the existing regime.
Manager tip
Section 33 creates the power to make this duty mandatory; it does not itself set every detail. Read it alongside the government's own guidance on creating an action plan, which is where the practical requirements are set out.

What an equality action plan must include

Government guidance sets out what belongs in a plan, ahead of it becoming mandatory.
  • A plan sets out actions covering gender equality, addressing the gender pay gap and supporting menopause.
  • Employers select at least two actions for their plan, with at least one addressing the gender pay gap and one addressing menopause support.
  • A plan can also highlight work already under way to improve workplace gender equality, alongside any new actions.
  • The detailed compliance requirements, including exactly what must be published and how, are left to regulations still to be made under the Act.

The timeline: voluntary now, mandatory from 2027

The government has set out when this shifts from an invitation to a requirement.
  • Employers with 250 or more employees have been able to publish an equality action plan voluntarily since 6 April 2026.
  • Subject to legislation, equality action plans become mandatory from spring 2027.
  • For the 2026 to 2027 reporting year, the government's own guidance gives a publication deadline of 4 April 2027 for private, voluntary and other public authority employers, and 30 March 2027 for most public authority employers, aligning with the existing gender pay gap reporting deadlines.
  • No commencement regulations bringing the mandatory duty into force had been made as of the date this guide was checked; the mandatory timeline remains subject to legislation.
Watch out
Spring 2027 and the 4 April / 30 March 2027 deadlines are the government's own published timetable, not yet a commenced legal requirement. Do not leave preparation until commencement is confirmed; the deadlines above are the ones to plan against.

What is genuinely still unsettled

Be plain about what is fixed and what is not, so you prepare against the right assumptions.
  • The regulations that will make equality action plans mandatory, and the fine detail of what must be published, have not yet been made.
  • Section 33 itself sets no commencement date; it only creates the power for the duty to be brought into force by regulations.
  • Treat the spring 2027 and 4 April / 30 March 2027 dates as the government's stated plan, and revisit this guide once commencement regulations are made so your plan reflects the final published requirements.
  • How the duty will apply to employers whose headcount moves across the 250-employee threshold between reporting years is not yet set out in detail.

Ethnicity and disability pay gap reporting: a separate change

This is easy to conflate with equality action plans, but it comes from different legislation.
  • On 25 March 2026, the government confirmed it will introduce mandatory ethnicity and disability pay gap reporting for large employers.
  • This commitment sits in the proposed Equality (Race and Disability) Bill, not the Employment Rights Act 2025 that creates equality action plans.
  • The proposed threshold mirrors gender pay gap reporting: employers with 250 or more employees, reporting six pay-gap metrics alongside new workforce composition data.
  • No implementation date has been confirmed; the government has committed only to legislating as soon as possible.
Watch out
Do not assume ethnicity and disability pay gap reporting shares the equality action plan's spring 2027 date. It is a separate, later-stage proposal with no confirmed commencement, so treat any date quoted elsewhere for it as unconfirmed until the Bill and its regulations are published.

Preparing your gender pay gap data now

An equality action plan builds directly on the numbers your gender pay gap report already produces.
  • Check the quality and completeness of the pay and bonus data behind your current gender pay gap figures, since an action plan will need to respond to them.
  • Identify where your gender pay gap is widest, for example within a particular pay quartile or bonus outcome, so any action plan can target the real gap.
  • Review what menopause support your business already offers, so you can evidence existing action as well as plan new steps.
  • If your business is approaching 250 employees, monitor your headcount against the snapshot dates, since crossing the threshold brings both the reporting duty and, from 2027, the action plan duty.
Manager tip
Start gathering this evidence well before spring 2027. An equality action plan is easier to build from data you already understand than from a review carried out under deadline pressure.

Getting ready for 2027: the essentials

A summary of the essentials covered in this guide:
  • Employers with 250 or more employees already report gender pay gap data annually under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.
  • The Employment Rights Act 2025 adds a duty to publish an equality action plan covering the gender pay gap and menopause support, voluntary from 6 April 2026.
  • Subject to legislation, that duty becomes mandatory from spring 2027, aligned with publication deadlines of 4 April (most employers) and 30 March (most public authorities).
  • Ethnicity and disability pay gap reporting is a separate, unconfirmed proposal under the Equality (Race and Disability) Bill, not part of the Employment Rights Act 2025.
  • Use the time before commencement regulations are made to review your gender pay gap data and existing menopause support, so your plan is ready when the duty applies.

How Jamie HR helps

Jamie HR keeps your gender pay gap data, action plan content and menopause support policies together, ready for the deadlines ahead.
  • Gender pay gap data captured through the year, so the figures behind your annual report and any equality action plan are ready when you need them.
  • Equality action plan content, including gender pay gap actions and menopause support, drafted and stored against each reporting year.
  • Policy library keeping menopause and gender equality policies current and easy for managers to point to as evidence.
  • Guidance kept current as commencement regulations for equality action plans, and any Equality (Race and Disability) Bill developments, are published.
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This guide is general information, accurate to the best of our knowledge as of 2026, and is not legal advice. Employment law changes and every situation is different, so for a specific case take professional HR or legal advice. Sources: gov.uk, legislation.gov.uk, the Equality Act 2010 and the Employment Rights Act 2025.