Equality Action Plans, tackling the gender pay gap
By Dr. Natasha Hirst on 23 April 2026
The Gender Pay Gap has far reaching, detrimental impacts for women over their entire lifespan. From the motherhood penalty to the gender pension gap and pay disparity throughout their working lives, the inequalities experienced by women are structural. It takes a deliberate, collective effort to address this.
Tom Heys, Pay Reporting Lead at Lewis Silkin LLP, points out that, “gender pay gap reporting wasn’t meant to be a box ticking exercise. Gender pay gap reporting is a means to an end, not the end in itself. It’s not the reporting of gaps that is the important or useful result, but what happens as a consequence of that.”
One of the new requirements of the Employment Rights Act 2025 aims to encourage employers to move from reporting to taking action to tackle gender inequality at work. From April 2026, employers with over 250 employees can voluntarily publish equality action plans, focussing on addressing the gender pay gap and supporting employees experiencing menopause symptoms. Organisations must track and report progress against their chosen actions. From April 2027, equality action plans will become compulsory.
Amy Butterworth, Inclusion and Wellbeing Director at Business in the Community, said, “it is great to see that large employers will be required to publish the steps they are taking to close gender pay gaps and to support employees through menopause, recognising it as a critical workplace health issue. Gender pay gap reporting has been mandatory for nearly a decade, yet women continue to face significant inequalities in pay and opportunity.”
The persistence of the gender pay gap suggests that any ‘easy wins’ have been exhausted. What remains is the much harder task of interrogating the systems and cultures that segregate women in workplaces and obstruct their progression to higher paid roles.
Butterworth adds, “requiring organisations to publish action plans should improve transparency, encourage the sharing of good practice, and help accelerate progress. But transparency alone will not deliver meaningful change. Employers must be accountable for creating workplaces where people of all genders can progress and thrive, rather than treating action plan reporting as a compliance exercise. It is vital that progress is monitored and impact is assessed over time, to ensure these new requirements lead to real improvements for women at work.”
From transparency to accountability
The stakes are now much higher for employers to ensure they approach gender equality at work robustly.
Heys explains how, “the shift to equality action plans moves the regime from transparency towards accountability. Publishing a pay gap without a credible plan to improve it will not only carry reputational risk, but now a legal risk.”
Assigning equality action plans to an isolated member of staff won’t cut it and employers should consider gaps in expertise and evidence in order to develop robust plans.
Heys notes that “leading employers are already deploying evidence backed measures, targeted on the key areas holding women back, and regularly assessing their impact, before then including details of their strategy in their gender pay gap reports. Done properly, the new framework gives employers a clearer roadmap towards the interventions that actually move the dial, rather than well-meaning but ineffective initiatives. There are no quick fixes. Reducing pay gaps requires sustained, structural change over several years. This is what the equality action plan regime is attempting to establish.”
On their website, Lewis Silkin LLP sets out how employers can prepare for the equality action plans, including auditing and documenting actions, gathering data, running training and engaging stakeholders such as unions and employee networks.
The Office for Equality and Opportunity published its guidance on equality action plans in March 2026. However, the Fawcett Society has expressed concern about the lack of consideration given to unequal outcomes created by the use of Artificial Intelligence in HR and recruitment processes. Their website highlights how algorithms based on decades of structural inequalities compound intersectional inequities.
As they call for the guidance to be updated, the Fawcett Society explains that, “an employer could follow every recommendation in this guidance, introduce structured interviews, improve transparency around pay bands, support line managers to have better conversations; and still be running a recruitment algorithm that systematically screens out women with career gaps, or a performance tool that penalises part-time working patterns. Inequality does not pause because it has been automated. Accountability should not either.”
Addressing the motherhood penalty
Kendal Wright, Lecturer at The Open University also agrees that gender pay gap data reporting alone cannot close the gap. “Understanding the root causes and developing a tailored action plan is crucial to focus attention and spur on change. Our Open University research shows that tackling the motherhood penalty at work is essential for progress on gender equality. That is, the disadvantages mothers can face at work, including in terms of pay and career progression, after having a child. Working mothers face structural and cultural barriers to equality, including the ‘supervisor lottery’ of inconsistent manager support, inflexible working, and unaffordable childcare which can disproportionately force women off career pathways. And our research shows these factors may be compounded further for ethnic minority mothers who can face triple penalties of gender, motherhood, and ethnicity.”
Understanding and addressing the motherhood penalty and drawing on existing good practice will support employers to develop impactful actions that support women at different stages of their life and career.
Wright concludes, “we’ve developed a practical toolkit, published in collaboration with the Department for Work and Pensions, to help employers tackle the motherhood penalty for all mothers. The toolkit could help inform employer action on the gender pay gap, offering practical guidance on parental leave, flexible working, and supporting returners.”
Gender pension gaps
From motherhood to retirement, inequality continues to deepen over women’s lifetimes. The persistence of gender inequality in the workplace leads to deeply unequal experiences in retirement.
NOW:Pensions CEO, Patrick Luthi said, “whilst awareness has increased, we often fail to consider the longer-term financial security for working women, which is the gender pensions gap. This matters because it directly affects women’s financial security and independence in retirement. When women have smaller pension savings or lower retirement income than men, they are more likely to rely on family support or state benefits. Our latest statistics released in March 2026 show that women retire with pension savings of £105,000, compared to £232,000 for men. This is a gap of £127,000.”
Luthi identifies how, “the primary drivers behind the gender pensions gap are differences in work patterns, such as fewer hours worked, more part-time jobs, caregiving responsibilities, and lower earnings over a lifetime.” These inequalities arise in part from societal expectations that place the burden of caregiving on women, but that’s not a get-out clause for employers.
Luthi said, “it matters to workplaces too. In an ageing society it’s important that people are helped to retire comfortably at a time that’s right for them. The advice you may give to Gen Z and Millennials is different to the advice you would give to those employees that are reaching retirement age.”
As deep-rooted and complex as gender pension inequalities are, change can happen and the effort employers put in will support better outcomes for women. Luthi concludes, “whilst the pension savings gap represents a significant challenge, there has been some progress over time as we see the gap slowly reducing. When we began publishing statistics on the Gender Pensions Gap in 2019, women’s pensions were almost one-third of men’s, whereas the latest statistics show that this has risen to 45%.”
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