GOV.UK guidance, Steps 1 to 6
Equality action plan rules: minimums, word limits and deadlines
The format the gender pay gap service uses for action plans, rule by rule, with the official page each one comes from and the date we last checked it. The builder applies exactly these rules, from one dated file.
The rules in one table
Rules as of 10 October 2026. Plans are voluntary for the 2026 to 2027 reporting year; the regulations that will make them mandatory may change any of this.
| Area | Rule | Source |
|---|---|---|
| Law | Section 78A 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”. | Equality Act 2010, s.78A, checked 10 October 2026 |
| Law | Section 33 of the Employment Rights Act 2025, which inserted section 78A, came into force on 6 April 2026. | S.I. 2026/323, reg. 3, checked 10 October 2026 |
| Law | No regulations under section 78A had been made or laid in draft when these rules were last checked, so the duty to publish a plan does not apply yet. | legislation.gov.uk, title search, checked 10 October 2026 |
| Timing | Voluntary now. “Subject to legislation, these will become mandatory from spring 2027.” | GOV.UK guidance, Overview, checked 10 October 2026 |
| Who | Employers with 250 or more employees. | GOV.UK guidance, Overview, checked 10 October 2026 |
| Who | It applies to a public authority only if the authority is listed in Part 1 of Schedule 19 to the Equality Act 2010, or in Part 4 of that Schedule with the letter “D” after the entry. | Equality Act 2010, s.78A, checked 10 October 2026 |
| Who | You must submit an action plan for each separate legal entity with 250 or more employees. | GOV.UK guidance, Overview, checked 10 October 2026 |
| Actions | Choose from the 18 actions on GOV.UK’s list, in five groups. | GOV.UK guidance, Step 2, checked 10 October 2026 |
| Actions | At least 2 actions: at least 1 that addresses the gender pay gap and at least 1 that supports employees experiencing menopause. | GOV.UK guidance, Step 2, checked 10 October 2026 |
| Actions | At least 2 actions must be ‘new or in progress’. ‘Embedded’ actions can be added as well, and do not count towards this. | GOV.UK guidance, Step 2, checked 10 October 2026 |
| Text | Each ‘new or in progress’ action needs supporting text: why you chose it and how you will track whether it is improving gender equality. For ‘embedded’ actions the text is optional: how it was embedded and its results. | GOV.UK guidance, Step 3, checked 10 October 2026 |
| Text | Up to 100 words of supporting text for each action, with no links and no files. | GOV.UK guidance, Step 3, checked 10 October 2026 |
| Text | An optional overall supporting narrative of up to 200 words, with no files. | GOV.UK guidance, Step 3, checked 10 October 2026 |
| Text | The service asks you to link to the relevant page on your own website, for example your organisation’s equality policies or strategies, if you have them. GOV.UK encourages you to publish the plan’s information on your own website too. | GOV.UK guidance, Step 3, checked 10 October 2026 |
| Approval | Private and voluntary sector employers must include the name of a responsible person when they submit the plan. It should usually be a director, partner or senior officer, who confirms that the information submitted is accurate. Most public authority employers do not need to do this. | GOV.UK guidance, Overview, checked 10 October 2026 |
| Deadlines | Private, voluntary and all other public authority employers: snapshot date 5 April, deadline 4 April the following year. For the 2026 to 2027 reporting year, 4 April 2027. | GOV.UK, When to report, checked 10 October 2026 |
| Deadlines | Most public authority employers: snapshot date 31 March, deadline 30 March the following year. For the 2026 to 2027 reporting year, 30 March 2027. | GOV.UK, When to report, checked 10 October 2026 |
| Review | Once plans are mandatory, GOV.UK says you will need to review and update the plan every reporting year. Based on current plans: an interim progress review 1 year and 2 years after the first mandatory plan, and a more detailed review of each action 3 years after it. | GOV.UK guidance, Step 6, checked 10 October 2026 |
| Review | You must be working on at least 2 actions at any time. | GOV.UK guidance, Step 6, checked 10 October 2026 |
The 18 actions, in GOV.UK’s five groups
The first four groups are the actions on the gender pay gap; the fifth supports employees experiencing menopause. Each name links to its action page, with the evidence, how to carry it out and how to track it.
| Group | Action | GOV.UK’s description |
|---|---|---|
| Recruiting staff Gender pay gap | Make job descriptions inclusive | Inclusive job descriptions can attract diverse talent by using neutral language, listing only essential requirements, and highlighting equal opportunities. |
| Encourage applications from a range of candidates | Actively seeking applications from under-represented groups can ensure a broader range of applicants for all roles. | |
| Reduce unconscious bias in CV screening | Using structured, skill-based screening can minimise bias and boost diversity in hiring. | |
| Use fair and structured interview techniques | Structured interviews support fair, objective hiring. Standardised questions and scoring helps reduce bias and promotes equal opportunity. | |
| Advertise leave policies in job adverts | Advertise parental, carer, and compassionate leave policies widely to ensure all prospective employees know the entitlements they would be eligible for. | |
| Advertise flexible working arrangements in job adverts | Flexible working policies can aid work-life balance, especially for people with caring roles. Advertising flexibility can attract a wider, more diverse group of applicants. | |
| Developing and promoting staff Gender pay gap | Automatically consider eligible employees for promotion | Automatically considering all eligible employees for promotion gives them the choice to opt-out rather than opt-in. |
| Encourage employee development through actionable steps | Giving all employees clear and actionable advice on how to develop may benefit organisations with low rates of progression and retention for women. | |
| Offer mentoring, sponsorship and other development programmes | Providing development programmes, such as mentoring, gives employees a formal channel for advice and support. | |
| Building diversity into your organisation Gender pay gap | Set targets to improve gender representation | Setting specific internal targets that you can monitor using data gives your organisation clear steps to improve gender representation and equality. |
| Increasing transparency Gender pay gap | Increase transparency for pay, promotion and rewards | Transparency in pay, promotion, and bonus policies helps ensure everyone understands how decisions are made. |
| Enhance and promote flexible working and leave policies | Enhance and promote leave policies and flexible working so employees know their entitlements and how to use them. | |
| Supporting employees experiencing menopause Menopause | Train managers to support employees experiencing menopause | Manager training can help organisations support employees experiencing menopause. |
| Offer occupational health advice for employees experiencing menopause | Giving employees specialised occupational health advice can help them manage menopause symptoms, get support and work more comfortably. | |
| Set up menopause support groups and networks | Menopause support groups in your organisation can help provide peer support, information and guidance. | |
| Offer workplace adjustments for employees experiencing menopause | Personalised workplace adjustments for employees experiencing menopause can support their wellbeing and ability to work. | |
| Conduct a menopause risk assessment for your workplace | Menopause risk assessments can identify workplace adjustments to help support your employees’ wellbeing. | |
| Review policies and procedures to meet the needs of employees experiencing menopause | Ensure your organisation’s policies align with the needs of employees experiencing menopause by reviewing your policies and procedures. |
Minimums and statuses
You must choose a minimum of 2 actions in your action plan: one must address your gender pay gap; one must support employees experiencing menopause.
GOV.UK, Step 2. Choose your actions
- New or in progress
- You will be working on it for the first time, or building on something you already do. At least 2 actions must have this status. The published plan lists them as planned actions.
- Embedded
- Already an established part of your working practice. You can add as many as apply; they show what you have already done, but do not count towards the 2 new or in progress actions.
So 1 embedded pay gap action and 1 embedded menopause action is not enough: the plan also needs 2 actions that are new or in progress. Once plans are mandatory, Step 6 adds that you must be working on at least 2 actions at any time, so changing an action’s status or removing one means adding a new action.
Supporting text and word limits
- Each new or in progress action must have supporting text on why your organisation chose it and how you will track and understand whether it is improving gender equality.
- Embedded actions can have text on how your organisation implemented the action and what the results have been.
- Up to 100 words for each action, with no links and no files such as CSVs or PDFs.
- An overall supporting narrative of up to 200 words, optional, for background and your objectives for gender equality. No files.
- A link to your own website, asked for separately, for example to your equality policies or strategy. GOV.UK encourages you to publish the plan’s information on your own site too.
How words are counted. The gender pay gap service loads the GOV.UK Design System, whose word counter counts every run of characters between spaces or line breaks as one word. So “part-time” is one word, “4 April 2027” is three, and a dash or an ampersand with a space either side counts as one. The builder counts the same way; the service makes the final check.
The responsible person, and groups of companies
Private and voluntary sector employers must include the name of a responsible person when they submit the plan. GOV.UK says the responsible person should usually be a director, partner or senior officer, and “will be responsible for confirming that the information you have submitted is accurate”. Most public authority employers do not need to do this.
An organisation with several legal entities must submit a plan for each entity with 250 or more employees. Each can have its own actions and text, or the same actions and narratives can be copied into a plan for each, for example where one diversity and inclusion strategy covers the whole group.
Who, where and when
- Employers with 250 or more employees, the same threshold as gender pay gap reporting. Section 78A does not apply below 250.
- Public authorities only if they are listed in Part 1 of Schedule 19 to the Equality Act 2010, or in Part 4 with the letter “D” after the entry. Public authorities in Scotland and Wales have different rules.
- England, Scotland and Wales. Section 78A extends to England and Wales and Scotland.
- Deadlines for the 2026 to 2027 reporting year: 30 March 2027 for most public authority employers (snapshot date 31 March 2026), 4 April 2027 for private, voluntary and all other public authority employers (snapshot date 5 April 2026). When plans become mandatory.
Questions
Can we write our own actions?
The guidance asks you to choose from the government’s list of 18 actions and does not describe adding your own. You can say how you will carry out each one in its supporting text, and add background in the overall narrative.
Can an embedded action count towards the two required actions?
It counts as one of your actions, and an embedded menopause action meets the menopause minimum. But at least 2 actions must be new or in progress, so a plan of one embedded pay gap action and one embedded menopause action does not meet the rules.
Can we put a link in the supporting text?
No. Step 3 says you cannot add links or upload files in the text for each action. The service asks separately for a link to the relevant page on your own website, such as your equality policies or strategy.
Sources: GOV.UK, Creating an action plan: guidance for employers (published 4 March 2026, updated 13 May 2026), Overview and Steps 1 to 6; GOV.UK, Action plans: list of actions (4 March 2026); Equality Act 2010, section 78A; GOV.UK, When to report (updated 21 May 2026); Business.gov.uk, Employer Action Plans (updated 5 October 2026). Last checked 10 October 2026. This page explains the guidance; it is not legal advice.