Why pay gap action plans can no longer continue to be a board-level tick box exercise

The pay gap reporting landscape is set for a significant upgrade, driven by the 2026 Employment Rights Bill. So what’s changing? Employers will soon be required to produce a mandatory action plan alongside their gender pay gap report, as well as include a menopause plan. These additions make it clear that organisations must now evidence decision-making, progress, and impact not just tick the box on reporting and data compliance. Weak or generic action plans won’t just fall short of expectations; they’ll expose boards to regulatory, reputational, and employee challenges.

The stats show us that for too long many organisations have approached their pay gap actions as 'just something else that needs to be written about.' At a panel discussion earlier this year with Verditer Consulting and Joanne Pagett - Performance & Menopause Coach,  Verditer shared some interesting statistics about the latest round of gender pay gap reports from 10,588 submissions:

• Only around 43% of organisations published a voluntary narrative
• 8% of those had contained broken links
• Only 31% had a voluntary action plan
• Only 10% mentioned menopause

With the new requirements all that is about to change. The question will no longer be about whether you publish a narrative or an action plan, but whether the equality action plan that you must publish will be able to withstand public scrutiny.

A recent client example comes to mind that highlights why this is important. After joining a new organisation as HR Director, they reviewed their data and discovered that the organisations gender pay gap was stalling year after year. At first it was unclear why. When we dug into the data and practices, the problem was obvious. The previous predecessor had simply copied and pasted their gender pay gap plan into reports year after year (obviously with board approval).  Rearranging a few words and sentences was the extent of their combined efforts. Unsurprisingly, they made no progress with their pay gap.

The problem here is that anything to  do with addressing pay gaps is viewed as a one time fix rather an an ongoing risk that requires ongoing attention and action. It's not uncommon for  audits to highlight that the main issue is inconsistency during recruitment and promotion cycles for so many organisations. Without a structural fix, they are simply destined to be in the same position next year and each cycle carries both reputational and legal exposure. Not understanding this makes it difficult to explain why the pay gap is not shifting. 

Yet, with these new regulation changes, clarity on what you are doing and why is going to be so much more important. Not just for the board, but for employees, stakeholders, investors and your future employees (who are watching you, whethere you know it or not). For the first time you'll be judged not by if you decide to write a narrative, but what you say AND how you follow through on it.