Equality action plans 2027: what is mandatory and when

What the government says, word for word

Employers with 250 or more employees have the option to produce and publish a voluntary action plan alongside their gender pay gap data. Subject to legislation, these will become mandatory from spring 2027.

GOV.UK, Creating an action plan: guidance for employers, Overview (updated 13 May 2026)

These will become mandatory from spring 2027, subject to secondary legislation.

Business.gov.uk, Employer Action Plans (updated 5 October 2026)

The same guidance sets the first year as voluntary: “You can voluntarily produce and publish your first action plan any time during the 2026 to 2027 reporting year”, by 30 March 2027 for most public authority employers and 4 April 2027 for private, voluntary and all other public authority employers. The Equality and Human Rights Commission puts it as “voluntary for employers from April 2026 and mandatory for employers with 250 or more employees, likely from spring 2027”.

What the law says today

Section 33 of the Employment Rights Act 2025 inserted section 78A, “Equality action plans”, into the Equality Act 2010. It came into force on 6 April 2026. It is a power: “Regulations may require employers to develop and publish a plan (an ‘equality action plan’) showing the steps that the employers are taking in relation to their employees with regard to prescribed matters related to gender equality”. Those matters include “addressing the gender pay gap” and “supporting employees going through the menopause”.

So the duty starts only when the regulations are made. A title search of UK statutory instruments and draft statutory instruments on legislation.gov.uk for “equality action plan” found none on 10 October 2026.

Who

Not employers with fewer than 250 employees. In the public sector, only the authorities in Part 1 of Schedule 19 to the Equality Act 2010, or in Part 4 with the letter “D” after the entry (s.78A(2)).

Where

England and Wales and Scotland. Business.gov.uk: “large private sector employers in England, Scotland and Wales, as well as English and specific cross-border public authorities”.

What the regulations may set

The content of a plan; how it is published; when and how often it is published or revised; senior approval before publication; and which employers, employees and information it covers (s.78A(5)). After the first publication, not more often than every 12 months (s.78A(6)).

Enforcement

By prescribed means “otherwise than as an offence” (s.78A(7)).

The dates

How advisers read “from spring 2027”

GOV.UK says when plans become mandatory, not which gender pay gap year the first mandatory plan goes with. Advisers read the same sentence in two ways, and we quote both:

• The first mandatory plan goes with the April 2027 snapshot, due by April 2028. Lewis Silkin (13 March 2026): “The first mandatory equality action plans will probably need to be published by April 2028.” Addleshaw Goddard (14 May 2026): “Subject to legislation, this will become mandatory from Spring 2027, meaning that publication will be due by April 2028.”
• Mandatory reporting in 2027. CIPD: “Voluntary reporting starts in 2026 with mandatory reporting in 2027.” Acas: “In 2027, publishing an action plan will become mandatory for employers with 250 or more workers.”

Both fit GOV.UK’s own statement that the 2026 to 2027 reporting year is voluntary. The regulations will settle the date, and they could also change the format. We check the official pages and will update this page and the rules on the day draft regulations are laid.

What to do before then

1. Decide whether to publish a voluntary plan with your 2026 figures. The format is the one the service uses now: at least 2 of GOV.UK’s 18 actions, at least one on the gender pay gap and one on menopause, at least 2 new or in progress, up to 100 words for each action.
2. Do the Step 1 analysis: the split of men and women at each pay level, starting pay, bonuses, promotion rates at the same grade, flexible working and leavers. Record it as your baseline.
3. Talk to staff about menopause support: the published figures say nothing about it.
4. Plan the review. GOV.UK says that, based on current plans, there will be an interim progress review 1 year and 2 years after the first mandatory plan and a more detailed review of each action after 3 years.

Build a plan in the current format

Questions