Employment Rights Act: a blueprint for effective equality action plans
23rd March 2026
Michelle Gyimah
The landscape of workplace equality reporting in the UK is about to shift significantly. Under the new Employment Rights Act, the familiar process of publishing gender pay gap figures is evolving.
From 2027, employers with 250+ employees will be legally required to go a step further by publishing a comprehensive equality action plan. This will present a significant change as only 18% of UK employers that publish pay gap data include an explanatory narrative or action plan (Government Equalities Office analysis of Gender Pay Gap Service data, 2023.)
With voluntary equality action plan reporting starting as early as April 2026, forward-thinking organisations are already preparing. A robust equality action plan does more than just acknowledge disparities; it demonstrates a genuine commitment to dismantling them.
This is the third article in the Verditer series looking at the impact of the Employment Rights Act on pay gap reporting. I’m considering what separates a truly effective plan from just being a box-ticking exercise.
Start with a deep dive, not a summary
A plan is only as good as the diagnosis it’s built upon. Publishing your pay gap data is the starting line, not the finish line. An effective plan begins with a thorough analysis of that data to uncover the root causes of inequality.
- Why do gaps exist (and how much of that is within our ability to manage)?
- Are women stalling at middle management?
- Are certain ethnic groups under-represented in graduate recruitment?
This requires going beyond the numbers and incorporating employee experiences and feedback to identify specific, systemic barriers to progression.
The new legislation also specifically mandates that plans address support for employees experiencing the menopause, meaning this area requires particular focus and thoughtful, informed action .
Set objectives rooted in both reality and aspirations
This is where many plans go wrong.
It is tempting to set ambitious, headline-grabbing targets, but a good plan prioritises credibility over creativity. Your objectives must be a direct response to the evidence uncovered in your deep dive.
If your qualitative data reveals that women often leave because of a lack of flexible hours, an objective focused solely on “recruiting more women” misses the point. Instead, the objective should tackle the root cause, such as “introducing consistent flexible job design across all mid-level roles to improve retention.”
Let the story your data tells dictate the targets you set. If the numbers show the biggest barrier is at the point of entry, your objective should focus on entry-level recruitment, not just executive presence. Objectives that are rooted in reality are far easier for employees to trust and for managers to implement.
Outline concrete actions and ownership
This is where the plan becomes a practical roadmap.
For each objective, you must detail the specific actions you will take to get there. Will you introduce a formal mentoring programme for under-represented groups? Implement blind recruitment processes to reduce bias? Launch a campaign to normalise flexible working at all levels?
Crucially, the plan must also assign clear ownership. It should name who is responsible for delivering each action and this should not solely be left to HR to manage.
Responsibility and accountability should be fairly spread amongst various departments such as Reward, Comms, Talent Management etc. and outline how progress will be monitored and reported back to your employees.
Commit to transparency and adaptations
Finally, a good plan is not a static document. It should be published and accessible to all employees, to foster a culture of transparency and trust.
More importantly, it must be a living document. Commit to reviewing the plan annually, reporting on progress against your objectives, and adjusting your approach based on what the data and your ongoing learning shows. This turns the process from a one-off compliance exercise into a continuous cycle of improvement.
Ultimately, the shift toward mandatory equality action plans is an opportunity. By embedding these principles, organisations can move beyond simply reporting their problems and start demonstrating tangible progress toward solving them, building fairer and more successful workplaces for everyone.
This is a guest article from equality expert, Michelle Gyimah. It is part of our series exploring the impact of the Employment Rights Act 2025 on Pay Gap Reporting:
- Employment Rights Act: navigating the new era of pay gap reporting
- Employment Rights Act: what makes a great gender pay gap voluntary narrative
- Employment Rights Act: a blueprint for effective equality action plans
- Employment Rights Act: here’s what menopause has to do with it
How we can help
At Verditer, we are specialists in reward including pay transparency and gap reporting. Contact us if you’re looking for external expertise to support with your gender pay gap or equality action plans.
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Related Insights
Employment Rights Act: navigating the new era of pay gap reporting
The first in our series exploring the impact of the Employment Rights Act 2025 on Pay Gap Reporting.
Employment Rights Act: what makes a great gender pay gap voluntary narrative
The second in our series exploring the impact of the Employment Rights Act on pay gap reporting looks at voluntary narratives.
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