Employment Rights Act: what makes a great gender pay gap voluntary narrative
09th March 2026
Samantha Gee
This is the second blog in our series looking at the impact of the Employment Rights Act on pay gap reporting.
Our first, outlined how employers with 250+ employees will soon be required to develop and publish a narrative, including an equality action plan, alongside their gender pay gap calculations.
This year the narrative is encouraged, but still voluntary, but from 2027 it will be mandatory. So, in this blog I’m sharing some thoughts on what makes a great voluntary narrative.
What is a voluntary narrative?
Once you’ve published your gender pay gap figures, an accompanying narrative is your opportunity to bring your figures to life and tell the story surrounding them. It’s a chance to share what you’re doing and the progress you’re making towards gender equity.
So, what makes a great gender pay gap narrative?
Start with the why
Employers who embrace the purpose of pay gap reporting, rather than treating it as a compliance exercise, will lay out in their own words why closing the gap and establishing gender equity is the right thing to do.
There’s very clear business benefits to reducing your gender pay gap (we’ve written about this previously here) and creating an inclusive, equitable workplace.
Please don’t use this as an opportunity to labour the point that you don’t have an equal pay issue. Although important, having equal pay does not demonstrate gender equity.
Include data-led context
Your gender pay gap reporting figures are simply headline figures that satisfy regulatory requirements. The real story is very much hidden underneath.
It’s only when you share additional analysis that a fuller, more insightful, picture about what is really going on emerges.
What did your additional analysis really uncover? Where does the proportion of women drop off in your internal levels, and which work areas are more affected than others? What trends can you see compared to prior years analysis?
And are you being truly honest and authentic? If your senior roles are partners and not employees, have you shared additional analysis that includes them? If you outsource key work areas, have you explained the impact on the figures?
Keep it authentic
No matter how tempting it is to publish defensive marketing and spin alongside your figures, this isn’t going to do you any favours.
An honestly written authentic narrative is a way of demonstrating an open and trustworthy culture. And it’s the way to address the underlying causes of your pay gap and make real progress.
And don’t forget to acknowledge progress against the prior year’s goals.
Translate insight into actions
The best gender pay gap narratives include an equality action plan. This means clearly outlining specific, achievable interventions, with defined success measures.
Equality action plans that show the steps being taken to reduce your gender pay gap, and the support you are providing to employees going through menopause, are being encouraged from March/April 2026 reporting, and mandatory from March/April 2027 reporting (subject to secondary legislation).
We’ve more on creating an effective equality action plan in our next article in this series.
What to avoid
Lastly, a few things you may wish to avoid:
- Simply repeating the published figures – your narrative is an opportunity to explain why they look the way they do
- Confusing gender pay gap with equal pay – they are related but distinct concepts
- Defending the numbers with excuses and justifications – such as saying the organisation gender profile matches that of applicants, or that ‘by level’ analysis has shown there is no equal pay issues
- Over-complicating your story – clarity and relevance beat jargon
- Publishing at the last minute – this can signal a lack of commitment and does not allow time to progress actions or reflect on context before the next analysis is due
Done well, a strong gender pay gap narrative, including a clear equality action plan, reinforces that gender pay gap reporting is about meaningful change, not box-ticking.
This article 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 plan.
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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.
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