UK Gender Pay Gap Reporting Changes

Quick Hits

• Under the UK Employment Rights Act, employers may introduce equality action plans on a voluntary basis in April 2026.
• From 1 January 2027, changes to gender pay gap reporting requirements for employers with 250 or more employees will make equality action plans mandatory.
• Plans must include measures to address gender pay gaps and details of the support offered to employees during menopause.

Employers are not currently obligated to publish action plans aimed at tackling the gender pay gap. As noted in the act’s explanatory notes, only half of all employers required to report have chosen to voluntarily publish plans. However, the act introduces a new mandatory requirement for larger employers to create and publish gender pay gap action plans. In addition, menopause action plans will be required to support women experiencing menopause in the workplace. Measures can be included in larger gender equality action plans and are not required to be published separately. This follows part of a larger plan to improve workplace equality and transparency. The UK government has also suggested making reporting on ethnicity and disability pay gaps compulsory for larger employers, with further announcements anticipated to be made separately.

If a gender pay gap is found, employers will need to provide evidence-based analysis of why any gap exists. They will need to examine the data and consider the factors that may have resulted in a pay gap, a process that may include auditing recruitment practices, policies, or progression opportunities. Further to this, employers must demonstrate any steps they have taken in the last twelve months to close their gender pay gap, such as staff training or updated policies.

The act will require employers to identify the providers of contract workers. Employers are only required to report on their own employees in their gender pay gap statistics. However, they must also reference the gender pay gaps of any outsourcing providers in their report.

Timeline for Reporting

From 1 January 2027, action plans on the gender pay gap and menopause become mandatory. Employers will need to publish clear, targeted measures and likely integrate them with broader equality strategies.

Further developments across the United Kingdom and the European Union signal a greater shift towards pay equity, with EU member states currently due to transpose the EU Pay Transparency Directive by 7 June 2026. Employers are encouraged to stay informed about the EU Pay Transparency Directive implementation process in their respective jurisdictions. Information and updates on the progress of the directive’s implementation across the European Union can be found using Ogletree Deakins’ Member State Implementation Tracker.

Ogletree Deakins’ London office, Pay Equity Practice Group, and Workforce Analytics and Compliance Practice Group will continue to monitor developments and will provide updates on the Cross-Border, Pay Equity, and Workforce Analytics and Compliance blogs as additional information becomes available.

Daniella McGuigan is a partner in the London office of Ogletree Deakins and co-chair of the firm’s Pay Equity Practice Group.

Lorraine Matthews, a practice assistant in the London office of Ogletree Deakins, contributed to this article.

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