Gender pay gap action plans – Update
We previously published an article highlighting the Government’s proposals to introduce requirements for large employers with 250 or more employees to create voluntary action plans that show how they reduce gender pay gap and support employees experiencing menopause. This voluntary proposal was ahead of the mandatory timeline which will take effect from April 2027.
At the time of publication the Government confirmed their intention to publish further guidance for employers to support development of these plans which is now available for the different industry sectors.
At the same time updated guidance was made available for businesses that are part of a group of connected companies providing advice on how these entities need to comply with the requirements.
It states, where an organisations has more than one legal entity with 250 or more employees, they are required to submit separate action plans for each legal entity within the group.
Organisations can choose to submit
- a separate plan for each legal entity, with different actions and supporting narratives that are relevant to that part of their organisation or group
- the same actions and supporting narratives, copied into separate action plans for each entity – for example, they might do this if they have one diversity and inclusion strategy for the whole group.
The general guidance sets out six steps for employers to consider when formulating action plans in order to demonstrate what measures they have implemented to address gender equality in the workplace.
Step 1 – Understand the issues in your department
This is geared towards understanding the dynamics of the business having an awareness of differences and possible emerging trends that may indirectly hinder performances or moral across the workforce. Is there a possibility that some groups may be unintentionally impacted when compared to others, this could be based on a lack of awareness.
Step 2 – Choose Your actions
There are 18 actions to choose from the requirement is to identify a minimum of two action plans from the initial step 1 approach, whilst engaging with the wider workforce, based on the findings from step 1, develop realistic action plans that identify direct flags and set out measures to address this. One of which should include supporting staff through the menopause.
Step 3 – Write a supporting narrative
This requires an explanation to support why the chosen action plans have been selected and what measures will be put in place to evaluate the success of any action taken together with realistic reviews that are effective and not just a meaningless exercise to fulfil the requirement.
Step 4 – Submit your action plan
Check that all measures have been adequately addressed before submitting. Submission will be through the gender pay gap reporting service. To submit, select the ‘responsible person’ tab this person will be responsible for approving your plan and will need to create an account which links to the organisation’s gender pay gap account.
Step 5 – Track the outcomes of your actions
As business needs change and develop each action plan submitted will have a tracking progress section to help businesses monitor whether they are keeping on track to meet their plans and whether the measures have resulted in real change that take on board the end goal as set out in the initial steps.
Step 6 – Review your plan
With the introduction of mandatory reporting from April 2027, updating action plans will become a key part of the process, business needs will constantly be evolving and, criteria used in one year to form existing action plans will change therefore ongoing monitoring of action plans to ensure that they are fit for purpose and continue to address new or existing action plans.
The Government guidance can be found here: https://www.gov.uk/government/publications/creating-an-action-plan-guidance-for-employers