What are Gender Equality Plans – and why the UK needs to get them right

Background

The Employment Rights Bill currently going through Parliament includes a significant new requirement: companies with 250 or more employees will need to create and publish Gender Equality Plans (GEPs). According to the Bill, these plans must address the gender pay gap and provide support for employees going through the menopause. The Bill offers little detail beyond these broad themes.

GEPs have the potential to drive real cultural and structural change in organisations — but only if they are well designed and properly implemented. In other countries, GEPs go further, tackling deeper causes of inequality through areas like recruitment, promotion, work-life balance, and leadership representation.

In this blog, I’ll explain what GEPs are, highlight international examples of good practice, and offer recommendations on how UK companies can use them to advance gender equality in a meaningful way.

GEPs are strategic documents developed by organisations to identify, address, and monitor gender inequalities in the workplace. These plans are part of a broader international policy trend aimed at increasing corporate accountability for issues such as the gender pay gap and modern slavery in supply chains.

 Why GEPs are important:

1. Transparency and Accountability: GEPs require organisations to collect and publish data on gender-related workplace issues, making inequalities visible and prompting action.
2. Targeted Improvements: They can compel organisations to reflect on working practices which perpetuate inequality and push them to implement concrete changes rather than make vague commitments.
3. Integration with Broader Employment Practices: In some contexts, GEPs are tied into collective bargaining, enhancing their effectiveness through structured employee-employer dialogue.

 Legislative Options for GEPs

One of the first decisions policymakers must make when designing GEPs is to define their scope. While addressing gender pay gaps is undoubtedly crucial, it is not sufficient on its own.

Although the average gender pay gap has narrowed slowly in recent years, disparities persist -particularly in specific occupational groups such as skilled trades and associate professional and technical roles.[1] The gap is also significantly higher for women over the age of 40 and for those in high-earning professions. Current UK legislation only requires large companies to publish data on their gender pay gaps, but does not require any follow-up action to close those gaps.[2] Although some UK organisations have said that they have taken action voluntarily, around half of organisations have not.[3] This significantly limits the legislation’s effectiveness. Hopefully the implementation of GEPs will address this problem.

To address gender inequality more comprehensively, GEPs should compel organisations to consider a broader range of workplace issues that contribute to structural disadvantage. A useful model can be found in Australia, where organisations with 100 or more employees are required to report on six criteria. These include:

• The gender composition of governing bodies;
• The availability of flexible working arrangements and other measures to support parents and carers;
• Policies and other strategies to prevent and respond to sexual harassment and discrimination.[4]

Including measures like these in GEPs would encourage organisations to take a more holistic approach to gender equality, addressing not just outcomes (such as pay gaps) but also working practices that sustain inequality. The UK government could learn from these international examples to ensure GEPs have a broad scope.

My recommendations to maximise the effectiveness of GEPs

Drawing on lessons from international legislation, I recommend incorporating the following principles into any UK legislation on GEPs to ensure they drive real progress:

1. Enforce Legislation Through a State Body

• Compliance is significantly higher when enforcement is underpinned by a dedicated state organisation with powers to monitor, investigate, and impose financial penalties or sanctions.

2. Provide Support to Employers

• Organisations will require training, resources, and technical support to meet GEP obligations.
• A designated state body should offer advisory services and practical toolkits.
• A government-sponsored recognition or award scheme could further incentivise employers by highlighting and celebrating best practices in gender equality.

3. Mandate Standardised Data Disclosure and Action

• GEPs should require mandatory reporting of standardised data against measurable criteria.
• Standardisation will:
  • Allow meaningful comparison across sectors and companies.
  • Promote transparency for employees, investors, and the public.
• Legislation should go further than data reporting—it should oblige companies to act, for example by:
  • Conducting gender-neutral job evaluations,
  • Calculating and publishing pay disparities, and
  • Making pay adjustments where inequities are found.

4. Ensure Worker Involvement in GEP Implementation

• The process should be collaborative: trade unions or worker representatives must be involved in data collection, interpretation and action planning.
• Their participation enhances accountability, ensures that employee experiences inform the process and ensures alignment with existing collective bargaining frameworks in some sectors.

These measures, taken together, would help ensure that GEPs are not simply a reporting exercise, but a genuinely transformative tool for improving gender equality in the workplace.

Jamie Atkinson is a Senior Lecturer in Law at Manchester Law School. He specialises in Employment Law and has published work which calls for more corporate reporting to address unlawful behaviour by employers in the area of labour law. Please do direct any queries or reflections to : J.Atkinson@mmu.ac.uk.

[1] Office of National Statistics, Gender Pay Gap in the UK: 2024

[2] Equality Act 2010 (Gender Pay Gap Information) Regulations 2017

[3] Government Equalities Office (2023), Post-Implementation Review of Gender Pay Gap Reporting

[4] Workplace Gender Equality Act 2012, s13