ERA 2025: Equality Action Plans — What Large Employers Must Do

The Employment Rights Act 2025 introduces mandatory equality action plans for employers with 250 or more employees. Unlike gender pay gap reporting, which requires you to publish a number, equality action plans require you to publish a plan — specific, measurable steps to address any pay gap identified.

The action plan must include data on the gender pay gap, a narrative explaining the gap, and concrete actions the employer commits to taking to reduce it. Vague statements of intent will not satisfy the requirement. The Equality and Human Rights Commission has indicated that it intends to take enforcement action against plans that lack genuine substance.

Smaller employers are not subject to the mandate — but the direction of travel is clear. Businesses with 50 to 249 employees who voluntarily publish an equality action plan signal something to both current and prospective employees. Mellow's pay equity analysis module — available in the Intelligence tier — runs pay gap analysis across gender, ethnicity, and tenure. It surfaces the data you need to write a credible plan.