The ERA 2025 introduces a new duty for large employers (those with 250 or more employees) to develop and publish equality action plans showing the steps they are taking in relation to their employees with regard to prescribed matters related to gender equality, which includes addressing the gender pay gap and supporting employees going through the menopause. Further regulations will be required as to the detail of the action plans to be published (including the form and manner and how frequently).
In addition, in the Next Steps document, the Government promised also to develop menopause guidance for employers as part of its existing powers and non-legislative reforms.
On 4 March 2026, some guidance was published in respect of supporting women with health conditions and menopause. This takes the form of recommended potential actions that may be included in employers’ equality action plans (see Pay Gap Reporting for further details), and includes steps such as manager training, offering occupational health advice and workplace adjustments, setting up support groups, conducting a menopause risk assessment and reviewing internal policies and processes. It is unclear if further menopause guidance will be published.
Timing and developments
Equality action plans
Included in the ERA 2025.
Further regulations will be required as to the detail of the action plans (including the form and manner and how frequently) and what information is required in relation to outsourced workers (see Pay Gap Reporting). The Government’s updated timeline and guidance indicates that the measure regarding gender pay gap reporting and menopause action plans will be introduced on a voluntary basis on 6 April 2026 and then will formally take effect in Spring 2027. It also states that menopause guidance will take effect on 6 April 2026, but it is unclear whether further guidance will be published in addition to the 4 March 2026 guidance noted above. Implementation of the gender pay gap outsourcing measure will depend on timelines for the draft Equality (Race & Disability) Bill (further details will follow in due course).
Guidance
This can be delivered outside of the legislative process and the Government’s updated timeline indicates that menopause guidance will take effect on 6 April 2026. It is unclear whether further guidance will be published in addition to the 4 March 2026 guidance noted above.