# How to write a gender equality and menopause action plan

> Write a gender equality and menopause action plan: who is covered, baseline data, choosing actions, owners, measures and publishing on the GOV.UK.

Source: https://lumihr.co.uk/guides/how-to-write-menopause-action-plan
Author: David Whitfield (https://lumihr.co.uk/about/david-whitfield)
UK law as at: 20 September 2026
Review by: 6 April 2027 (or sooner if regulations making action plans mandatory are made)

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*By David Whitfield · Reflects UK law as at 20 September 2026 · Review by 6 April 2027*

> **In short**
> - Employers in England, Scotland and Wales with 250 or more employees can publish a voluntary action plan with their gender pay gap data. GOV.UK says that, subject to legislation, plans become mandatory from spring 2027.
> - A plan needs at least two actions from the government's list of 18: one or more on the gender pay gap and one or more supporting employees experiencing menopause.
> - In the lumi reward benchmark, 3.0% of organisations have already published a voluntary menopause action plan (n = 267).
> - By the end you will have a baseline, chosen actions with owners and measures, and a plan ready to submit.

## Before you start

**Legal basis.** Section 33 of the Employment Rights Act 2025 inserts section 78A into the Equality Act 2010. It allows regulations requiring employers with 250 or more employees to publish a plan on the gender pay gap and support for employees going through the menopause. Section 33 came into force on 6 April 2026, but until regulations are made, plans are voluntary and follow the government guidance, *Creating an action plan*.

Equality law already applies. The Equality and Human Rights Commission (EHRC) says that menopause symptoms could be a disability if they have a long-term and substantial effect on normal day-to-day activities, bringing a duty to make reasonable adjustments. Age and sex discrimination protection also applies, and health and safety law requires a risk assessment.

**Who to involve.** Reward, HR, payroll, occupational health, health and safety, data protection, networks and trade unions. Private and voluntary sector employers also need a "responsible person", usually a director, partner or senior officer, to confirm the plan is accurate.

**What you need.** Gender pay gap data; absence and retention data by age and sex; current policies; staff survey results.

## Step 1: Confirm you are covered and set your deadline

You are in scope if you report a gender pay gap: 250 or more employees on your snapshot date (31 March for most public authority employers, 5 April for everyone else). Public authorities in Scotland and Wales have different rules. Each legal entity with 250 or more employees needs its own plan, though a group can copy the same actions into each. For 2026 to 2027, the voluntary deadline is 30 March 2027 for most public authority employers and 4 April 2027 for everyone else.

In the lumi reward benchmark, 77.2% of organisations have no plans to publish a voluntary menopause action plan, the common answer; 13.9% are considering one, 6.0% plan to publish this year and 3.0% have already published (n = 267; [full findings](/research/fertility-menopause-support-2026)).

**◆ Decision: publish voluntarily now, or wait?**
- *Publish by the 2027 deadline.* Tests your data and sign-off early, but any weaknesses are public.
- *Draft internally only.* No public exposure, but no external credit.
- *Wait for the regulations.* Avoids rework if the rules change, but leaves less time to gather data.

## Step 2: Build your gender pay gap baseline

Start with your six reported figures: the mean and median hourly pay and bonus gaps, the share of men and women receiving a bonus, and their share of each hourly pay quarter. Then look for causes by sex across the employee lifecycle: recruitment, starting pay, performance ratings, promotion, flexible working and leavers.

In the lumi reward benchmark, 77.5% of organisations conduct gender pay gap analysis at least annually, the common answer (n = 267). 45.7% review incentive outcomes by protected characteristic, 30.7% partially and 23.6% not at all (n = 267). For promotion rates, the common answer is "planned but not yet" (42.5%); 12.2% monitor them routinely (n = 254; [full findings](/research/pay-gap-reporting-2026)).

**Worked example.** Sixteen full-pay relevant employees, with illustrative hourly pay in pounds:

- Men: 12.50, 14.00, 16.80, 19.20, 22.50, 26.00, 31.00, 38.50
- Women: 12.20, 12.80, 13.60, 15.40, 17.90, 20.60, 24.80, 29.00

Gap = (men's pay − women's pay) ÷ men's pay × 100. Calculated in Python: mean £22.56 against £18.29, a gap of 18.9%; median £20.85 against £16.65, a gap of 20.1%. Women are 75.0% of the lower pay quarter and 25.0% of the upper. Investigate those quarters before choosing an action.

## Step 3: Build your menopause baseline

Not all employees will want to share their menopause status. The government guidance uses women aged 40 to 60 as the target group for measures. Before you start, collect absence and retention rates, and use of flexible working and adjustments, by age and sex. Acas advises recording menopause-related sickness absence separately from other absence. Health data is special category personal data, so check your data protection position first.

Ask employees too, through focus groups or surveys.

**Worked example.** Of 64 women aged 40 to 60 at the start of an illustrative year, 55 remained 12 months later (85.9%), against 162 of 180 other employees (90.0%), calculated in Python. These are your retention baselines.

## Step 4: Choose your gender pay gap action

Alongside the six menopause actions, the list has 12 gender pay gap actions. Choose at least one that addresses your gap [4]:

- **Recruiting (6):** inclusive job descriptions; a wider range of candidates; less bias in CV screening; structured interviews; advertising leave policies in job adverts; advertising flexible working arrangements in job adverts.
- **Developing and promoting (3):** automatic promotion consideration; actionable development steps; mentoring and sponsorship.
- **Diversity (1):** gender representation targets.
- **Transparency (2):** pay, promotion and reward transparency; enhancing and promoting flexible working and leave policies.

Advertising leave policies and advertising flexible working are two separate actions, not one.

Each action is "new or in progress" or "embedded" (already standard practice). At least two actions in the plan must be new or in progress.

**◆ Decision: how many actions?**
- *The minimum of two.* Easier to resource, but less to show, and when one becomes embedded you must add another.
- *Several, mixing new and embedded.* Shows existing work, but means more to review.

## Step 5: Choose your menopause support actions

The six menopause actions are: train managers; offer occupational health advice; set up support groups and networks; offer workplace adjustments; conduct a menopause risk assessment; and review policies and procedures [4].

**◆ Decision: a menopause policy?**
- *A standalone policy.* Visible, and Acas suggests one helps workers feel supported. Another document to maintain.
- *Support within existing health, absence and flexible working policies.* Fewer documents, but harder to find.

**◆ Decision: adjustments beyond the legal duty?**
- *Case by case*, after a conversation or occupational health advice. Fits the individual, but relies on the employee asking.
- *A standard set on request*, such as flexible hours or a rest area. Consistent, but may not meet every need.

**◆ Decision: leave?**
No action on the list is menopause leave, but the policy review action covers leave provisions. In the lumi reward benchmark, 79.2% of organisations have no specific provision for menopause-related paid leave, the common answer; 17.7% provide support without specific paid leave and 3.1% offer specific paid menopause leave, both rare (n = 260).
- *Sick leave, recorded separately.* No new entitlement, but you must decide whether it counts towards absence triggers.
- *Flexible or unpaid time off.* Low cost, but unpaid time may deter lower-paid staff. Acas notes there is no statutory right to time off for medical appointments.
- *Specific paid leave.* Clear and visible. Higher cost, and may require disclosure.

**◆ Decision: health support?**
In the lumi reward benchmark, 77.1% of organisations provide no women's health support beyond menopause leave, the common answer; 12.8% offer a clinical benefit and 10.2% policy or awareness support only, both rare (n = 266).
- *Occupational health advice.* Builds on an existing service, but depends on referral capacity.
- *A clinical benefit*, such as a menopause pathway. Direct specialist access, at extra cost.
- *Policy and awareness only.* Low cost, but no clinical route.

**◆ Decision: manager training?**
GOV.UK suggests covering the law, symptoms, sensitive conversations and available support.
- *Required for all people managers.* Consistent and easy to measure, but takes every manager's time.
- *Targeted or optional.* Lower cost, but coverage is uneven.

## Step 6: Give each action an owner, measures and dates

For each action, record a named owner, start and review dates, the baseline and the measures, and review them monthly or annually. GOV.UK suggests measures for each action. For manager training: managers trained, knowledge before and after, staff feedback, and absence and retention for women aged 40 to 60.

**◆ Decision: targets or measures only?**
- *Numeric targets with dates.* Clear, but a miss is visible at review.
- *Measures only.* More flexible where numbers are small, but progress is harder to show.

## Step 7: Write the supporting text

Each action takes up to 100 words of supporting text. You can't upload files, such as CSVs or PDFs, or add links. For a new or in-progress action, you must say why you chose it and how you will track whether it is improving gender equality. For an embedded action, you can describe how you implemented it and what the results have been. An overall narrative of up to 200 words is optional [9].

## Step 8: Submit, publish and review

The submitter creates an account on the gender pay gap service and links your organisation to it. In the guidance's words: "Your published action plan will be available to the public along with your gender pay gap data."

Once plans are mandatory, you will need to update yours every reporting year, with planned interim reviews after one and two years and a detailed review after three. You must be working on at least two actions at any time.

## Checklist

- [ ] Legal entities in scope and deadlines identified
- [ ] Decision made on a voluntary plan for 2026 to 2027
- [ ] Gender pay gap figures and lifecycle data analysed
- [ ] Menopause baseline collected by age and sex
- [ ] Menopause-related absence recorded separately
- [ ] Employees, networks and trade unions consulted
- [ ] Gender pay gap and menopause actions chosen
- [ ] Owner, dates, baseline and measures set for each action
- [ ] Supporting text written and responsible person confirmed
- [ ] Plan submitted and review dates set

## FAQ

**Are menopause action plans mandatory?**
Not yet. They have been voluntary since April 2026. GOV.UK says that, subject to legislation, they become mandatory from spring 2027.

**How many actions does a plan need?**
At least two: one or more on the gender pay gap and one or more on menopause support. At least two must be new or in progress.

**Do we have to offer menopause leave?**
The action plan does not require it. No action on the list is menopause leave.

**Can menopause be a disability?**
It can. EHRC guidance says symptoms with a long-term and substantial effect on normal day-to-day activities could be a disability, bringing a duty to make reasonable adjustments.

## Related

- [Fertility and menopause support: UK benchmark 2026](/research/fertility-menopause-support-2026) — the benchmark findings behind the figures in this guide.
- [How to prepare and publish your gender pay gap report](/guides/how-to-prepare-gender-pay-gap-report)
- [How to publish salary ranges in job adverts](/guides/how-to-publish-salary-ranges-job-adverts)
- [How lumi works: methodology](/methodology) — how these figures are collected and calculated.

## Sources

1. lumi reward benchmark, collection window 2026 H1, national figures: [full findings](/research/fertility-menopause-support-2026)
2. lumi reward benchmark, collection window 2026 H1, national figures: [full findings](/research/pay-gap-reporting-2026)
3. Office for Equality and Opportunity, *Creating an action plan: guidance for employers* (4 March 2026, updated 13 May 2026). https://www.gov.uk/government/publications/creating-an-action-plan-guidance-for-employers
4. Office for Equality and Opportunity, *Action plans: list of actions* (4 March 2026, updated 23 July 2026). https://www.gov.uk/government/collections/action-plans-list-of-actions
5. Government Equalities Office and Women and Equalities Unit, *Gender pay gap reporting: guidance for employers* (updated 21 May 2026). https://www.gov.uk/government/publications/gender-pay-gap-reporting-guidance-for-employers
6. legislation.gov.uk, *Employment Rights Act 2025*, section 33. https://www.legislation.gov.uk/ukpga/2025/36/section/33
7. Equality and Human Rights Commission, *Menopause in the workplace: guidance for employers* (22 February 2024, updated 25 August 2025). https://www.equalityhumanrights.com/guidance/menopause-workplace-guidance-employers
8. Acas, *Menopause at work: supporting workers* (updated 7 April 2026). https://www.acas.org.uk/menopause-at-work/supporting-staff-through-the-menopause
9. Office for Equality and Opportunity, *Creating an action plan: guidance for employers — Step 3: write a supporting narrative* (4 March 2026, updated 13 May 2026). https://www.gov.uk/government/publications/creating-an-action-plan-guidance-for-employers/step-3-write-a-supporting-narrative

*This guide is general information about UK employment law and practice as at the date shown. It is not legal advice. Take advice on your own circumstances.*

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