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International Women’s Day 2026: From reporting to action on the gender pay gap
Last week, ahead of International Women’s Day, the UK Government marked a significant shift in pay gap reporting, as it published its new guidance for employers on creating gender pay gap action plans. From April 2026, large employers will be invited to voluntarily publish action plans setting out how they intend to tackle their gender pay gaps and support employees experiencing menopause, with a move to mandatory requirements from April 2027 under provisions in the new Employment Rights Act.
For Close the Gap and others who have spent years calling for reporting to move beyond transparency alone, this is an important moment with great potential for change – but whether it becomes a real turning point will depend on what happens next.
A brief history: transparency without teeth
The UK Government introduced mandatory gender pay gap reporting in 2017, requiring large employers to publish data on differences in average hourly pay, bonuses, and the distribution of men and women across pay quartiles.
This was a major step forward. It made pay inequality visible. It created public scrutiny. It put the issue on the agenda of boards and senior leadership teams, many for the first time.
But from the outset reporting was not enough. At Close the Gap, our five-year assessment of Scottish employer reporting showed that, while awareness had increased, progress was slow and uneven. Too many employers were publishing figures without meaningful analysis of the causes of their gap, and a large majority of employers didn’t publish any action to address pay inequality in their organisation. Transparency alone has not closed the gap.
That’s why we have consistently advocated for mandatory action plans, supported by effective accountability mechanisms.
What’s changing in 2026?
Under the new approach, employers will be required to:
- Publish an action plan alongside their gender pay gap data.
- Select at least two actions from a government-hosted portal of suggested interventions.
- Provide progress updates on those actions in subsequent years.
- Publish their plans and updates on the gender pay gap portal.
This approach will be voluntary from April 2026, and mandatory from April 2027. The Government has already launched its guidance to support employers, including encouraging diagnosis of the causes of their pay gap, setting timelines, and considering the impact of menopause, intersectionality, and culture change.
This is welcome progress. For the first time employers will be required not just to disclose gender inequality, but to say what they’re doing about it.
The opportunities and risks
The introduction of action plans on the gender pay gap and menopause represents an important and positive shift. Action is now part of the framework, signalling that reporting must lead to action, and that government may strengthen regulation if progress stalls.
This is a critical moment for women’s labour market equality, and there is much potential for progress. But the way employers respond to the new regulatory framework will determine whether it becomes a compliance exercise or a catalyst for real change.
A floor or a ceiling?
The regulations cover employers with 250+ employees, from those just above the threshold to organisations with many thousands of staff. Yet the minimum requirement is the same for all: two actions, one on their gender pay gap and one on menopause.
While two actions may be proportionate for a smaller employer with fewer resources and structures in place, larger employers with significant resources have the ability to go further, faster – if they choose to.
We know that there are already examples out there of employers taking meaningful action that has narrowed their pay gaps and created more equal workplaces for women. But there is a risk that those employers who are less motivated could treat the minimum requirement of two actions as a ceiling, rather than a floor.
This is a moment of opportunity. The UK Government can be clear in its messaging that the framework sets a minimum, not a maximum. Employers that are serious about tackling their gender pay gap can go further by selecting multiple, high-impact actions and embedding them within wider workforce strategies. Those that do so will not only make faster progress, but demonstrate leadership in a space where employees, customers and clients increasingly expect it.
Getting the foundations right: data analysis
We know that the better quality and more successful actions are those that are evidence based. However, one crucial action that is missing is a requirement that employers undertake an analysis of their gender pay gap in order to identify its causes. Without mandatory analysis action risks being poorly targeted and low or no impact.
This leads to the question of how an employer should know which actions to choose. If an employer hasn’t done an analysis, they are more likely to select actions that don’t reflect the issues at play in their organisation.
We know that employers who take evidence-based action see a greater return on their investment in equality than those who don’t. Understanding and using your data is the most efficient way to close your gender pay gap. And seeing that change come through in your data year on year is a great motivator to keep going.
Next month, the UK Government will be publishing further guidance setting out how employers can analyse their gender pay gap data and use this as a basis for their action plans. This is an opportunity to help employers to get their foundations right, so analysis becomes part of the furniture, and they can focus on other actions.
The role of scrutiny and accountability
The evidence tells us that transparency without enforcement does not guarantee progress. We are concerned that there are no clear mechanisms to assess the quality of gender pay gap and menopause action plans, no minimum standards for impact, and no consequences for employers than don’t follow through on their commitments. That presents a risk that these action plans become procedural rather than transformative.
However, public accountability is important. Action plans and progress updates will sit alongside gender pay gap data, open to scrutiny by employees, trade unions, the media and future recruits. This could be a motivator for employers in an era of heightened equality scrutiny, where brand reputation is critical.
The next few years will show whether reputational pressure and public scrutiny are sufficient, or whether stronger accountability measures will ultimately be required.
Many Scottish working women are being left behind
The UK gender pay gap reporting regulations cover all employers with 250+ staff in Scotland, England and Wales, as well as public bodies in England and Wales. Scottish public bodies publish their gender pay gap under the Scottish-specific duties of the public sector equality duty.
The result is that Scottish public bodies will not be mandated to publish gender pay gap action plans, leaving a big gap in action and accountability. Most Scottish public bodies aren’t taking action to close their pay gaps. The UK Government has made a change to make action plans mandatory – it’s time for Scottish Government to do the same for our public bodies. Women working in Scotland’s public sector, many of whom are in undervalued, low-paid work, cannot be left behind.
The year ahead: a test phase
The voluntary reporting year from April 2026 is critical. It provides an opportunity to see how employers respond when action plans are encouraged but not yet mandatory. Do they go beyond the minimum? Do they diagnose the root causes of their gap? Do they choose ambitious, evidence-based actions?
We know there are some great examples of employers who have used gender pay gap reporting as a basis for action in their organisations, who have made big strides in closing their gender pay gaps and in creating more inclusive workplaces for women. This is therefore a real opportunity to secure this kind of change on a greater scale. However, there is persistent evidence that many employers will not take steps on equality unless legally required.
We therefore hope the Government uses lessons from the 2026 voluntary phase to reflect on what has worked, and what adjustments are necessary to ensure we have a framework that can deliver on its ambitions, before the requirements become mandatory in April 2027. Close the Gap will be continuing our advocacy efforts in this space.
How we can support employers
Close the Gap has been supporting employers to understand and close their gender pay gap for 25 years. We work one on one with employers every day; delivering gender pay gap analysis, helping employers set targeted actions, and stepping them through implementation so they get things right.
We’ve also developed a self-assessment tool for employers who have to report their gender pay gap, Close Your Pay Gap. This free to use tool allows employers to answer a series of questions, and receive personalised feedback, and priority themes and actions that get to the heart of what’s going on in their organisation. The tool is ideally placed to support employers who are setting their actions, either for the first time, or for their next phase.
Over the next year we’ll be developing new guidance that steps employers through how to use the tool alongside the gender pay gap portal to select actions that are right for them, and how to put their commitments into practice.
From action to impact
International Women’s Day is intended to be a moment of celebration. This year, it’s also a moment of transition. The move toward gender pay gap and menopause action plans acknowledges what gender equality advocates have long argued: we need a regulatory driver to motivate action, and gender pay gap data must lead to change.
Transparency was the first step. Now we need impact. We’ll be watching what happens over the next year, and will continue to advocate for workplace equality for all women.
The refreshed Think Business, Think Equality tool is here
This morning, Close the Gap officially launched the refreshed Think Business, Think Equality tool – our free, practical self-assessment designed to help small and medium-sized employers take meaningful action on workplace gender equality.
Originally launched in 2015, Think Business, Think Equality has supported more than 12,000 businesses to better understand women’s labour market inequality and identify practical steps to address it. Over the past decade, the policy landscape has evolved, the evidence base has strengthened, and employers are navigating new economic and workforce challenges. This refresh ensures Think Business Think Equality remains ambitious, relevant, and aligned with Scotland’s Fair Work agenda.
Why this matters now
In the context of ongoing skills shortages, rising in-work poverty and new employment law requirements, advancing gender equality at work is both the right thing to do, and a smart, strategic decision for Scotland’s employers.
It’s the right thing to do because, in 2026, women still face gender inequality at work. The gender pay gap is not an accident; it reflects the workplace practices and societal barriers that shape women’s working lives. The consequences are greater economic insecurity, higher levels of in-work poverty, and persistent child poverty.
Gender inequality at work does not stay at work. It shapes women’s lifetime earnings, economic security and life chances – and affects families and communities across generations. When women are locked out of better-paid roles, passed over for progression, or pushed out by inflexible or hostile workplaces, the consequences are long-lasting.
Inequality also does not affect all women equally. Racially minoritised women, disabled women, single parents, and young mothers face compounded barriers – from discrimination in recruitment and progression, to a lack of reasonable adjustments and inflexible working practices. Too often, those who could benefit most from fair workplaces are those most likely to be excluded.
This shows us that there is a clear moral case for action. Employers are part of society, and the decisions they make about pay, progression and workplace culture have real impacts on people’s lives.
In addition, there is also a strong business case. Skills shortages are exacerbated by occupational segregation. You cannot solve a workforce challenge if you are recruiting from only half the talent pool. The gender pay gap is not just a fairness issue – it is a talent and productivity issue. Inclusive employers attract a wider range of applicants, retain staff for longer, and perform better.
The refreshed Think Business Think Equality tool is designed to support employers to take practical, proportionate action that works for their organisation.
What’s new?
The updated tool reflects what we’ve learned through years of employer engagement, research and policy advocacy. It:
- Focuses on the systems and practices that shape inequality, not just headline figures.
- Strengthens guidance across pay and reward, recruitment and retention, development and progression, flexible working, workplace culture, pregnancy and maternity, domestic abuse and sexual harassment.
- Embeds clearer, more tailored feedback and action planning for SMEs.
- Encourages employers to identify where bias or informal decision-making may be affecting outcomes.
- Aligns closely with the Fair Work Framework – particularly the Opportunity and Respect dimensions.
As before, the tool generates a personalised action plan based on an employer’s responses, helping them prioritise actions that will have the greatest impact.
Designed with SMEs in mind
Small and medium-sized businesses are the backbone of Scotland’s economy. Yet many lack in-house HR capacity or specialist equality expertise.
Think Business, Think Equality translates complex equality and employment law obligations into practical workplace steps. It supports employers to move beyond minimum compliance or funding conditionality, and instead embed equality into everyday employment practice – from how roles are advertised, to how pay decisions are made, to how flexible working is managed in practice.
From evidence to action
Close the Gap’s research consistently shows that workplace inequality is driven by organisational systems and practices, not individual choices.
Small, intentional changes to recruitment processes, pay structures, progression pathways, and workplace culture can make a significant difference to women’s access to fair, secure and rewarding work.
The refreshed Think Business, Think Equality tool is here to support that change.
The tool is free to use and available now. Take your first self-assessment today.
New webinar series - Men’s jobs and women’s job: how work got this way and what we can do about it
Tackling occupational segregation is central to Close the Gap’s work. The tendency for men and women to do different types of jobs and work at different levels is a defining feature of Scotland’s labour market. Women’s employment is concentrated in undervalued, low-paid, and underpaid jobs such as care, cleaning, and nursing. This segregation drives women’s poverty and child poverty, it restricts women’s (and men’s) choices, and it sustains the gender pay gap. Despite being such a significant cause of women’s labour market inequality, occupational segregation seems to be an intractable problem on which there has been little to no progress. In some areas, for example, tech, progress has actually reversed.
Occupational segregation is a cradle to the labour market problem, and policymakers have failed to get to grips with the level of action that’s needed to address this from early years to stopping the leaky pipeline. Instead, policy responses have largely focused on supply-side initiatives to equip more girls with STEM skills. There has been far less attention on the structural change that needs to happen in the workplace, and in wider policy areas such as childcare. There has been even less attention on the economy-wide undervaluation of ‘women’s work’ such as social care and childcare. This economic injustice persists even though, as Covid exposed, women’s work is essential to Scotland’s economy and to our society.
In 2026, we want to bring this ‘wicked problem’ into focus. We know that occupational segregation is not well understood by policymakers, employers or other key actors in women’s employment. From our work with employers, we’ve found that many are unclear about what the causes are, and importantly, how they can make a dent in the rigid patterns they see in their organisation.
This year marks the 25th anniversary of Close the Gap. Throughout the year, we will commemorate this milestone with a series of events, blog posts and activities to reflect on our journey so far and set out our vision for the future. To kick things off, we are launching a three-part webinar series exploring occupational segregation in more detail. This series, Men’s jobs and women’s jobs: how work got this way and what we can do about it, is designed to build capacity in employers by providing practical information and good practice examples from different sectors. We have an expert programme of speakers from employers from different sectors, trade unions, and organisations working on gender equality.
Webinar Details
You can find more information on each webinar and links to register below:
1. What is occupational segregation?
Date: 17th March 13:00-14:00
This session will introduce the topic and explore the causes and why occupational segregation persists. We will have expert speakers including:
- Anna Ritchie Allan, Executive Director at Close the Gap
- Dilraj Sokhi Watson, Director of Equate Scotland, the national organisation working on women in STEM sectors
- Susie Heywood from Gender friendly Scotland, who work on challenging gender stereotypes in early years
To register for the webinar, visit https://events.teams.microsoft.com/event/d17901c4-457b-401c-a7b0-b6bac3006359@35d08309-45f5-434a-bab9-1788fe402fb6
2. Addressing occupational segregation in male-dominated sectors
Date: 28st April 13:00-14:00
In this webinar we will be hearing from organisations who have been successful in rolling out targeted approaches to increasing the number of women in their male-dominated workforce. We are pleased to be joined by:
- Gareth Hind, Director of Colleague Experience and Internal Communications at First Bus
To register for the webinar, visit https://events.teams.microsoft.com/event/7f1002cd-365d-46f8-bb56-09c96e90a959@35d08309-45f5-434a-bab9-1788fe402fb6
3. How undervaluation drives occupational segregation
Date: 12th May 13:00-14:00
In our third session we will be exploring undervaluation. The concept of undervaluation underpins gendered pay inequality, occupational segregation and the gender pay gap. The skills needed to do ‘women’s work’ such as social care, childcare and nursing are less valued than comparative jobs done by men. This means that ‘women’s work’ is often associated with lower pay and poorer terms and conditions. This causes sector-wide issues such recruitment and retention challenges and ongoing equal pay claims. We will be hearing from:
- Lauren Mackie, Women’s Campaign Unit at GMB Scotland
- Eileen Mckenna, Associate Director of Nursing, Policy and Professional Practice at Royal College of Nursing
To register for the webinar, visit https://events.teams.microsoft.com/event/12dbda8f-da64-4388-a542-a8fa1dc53769@35d08309-45f5-434a-bab9-1788fe402fb6
The webinars will be recorded and available after the session.
EVENT: Fair Work in Action – Supporting employers to advance gender equality
Close the Gap is relaunching the Think Business, Think Equality tool for SMEs at a free online event showcasing how employers can strengthen Fair Work practices and advance gender equality at work.
Following an extensive redevelopment phase working closely with SMEs, the improved tool is now more accessible, streamlined, and tailored to the realities of small businesses. It provides businesses with a personalised action plan to take targeted action across key areas including pay and reward, recruitment and progression, flexible working, workplace culture, pregnancy and maternity, domestic abuse and sexual harassment. The tool also supports SMEs to meet Fair Work requirements and become funding-ready and contract-ready.
The event will feature a presentation of the tool and demonstrate how it can be used in practice, exploring how improving workplace equality strengthens Fair Work practices and business sustainability. There will also be a panel discussion and opportunities for questions.
Anna Ritchie Allan, Executive Director at Close the Gap, will be chairing the event, and the Minister for Business and Employment has been invited to give a keynote address.
Lindsey Millen, Head of Policy and Development at Close the Gap, will be presenting the Think Business Think Equality tool.
We will also have a panel discussion with confirmed speakers Carolyn Currie, Chief Executive Officer at Women’s Enterprise Scotland; Susan Harkins, Head of Innovation and Entrepreneurship at South of Scotland Enterprise; and Eleonora Vanello, Head of Peer Works.
Event Details
Date/time/location: Tuesday 24th February, 10.00am-11.30am, online.
You can register for the free event here.
Joining instructions will be sent to all registered attendees in advance of the event.
If you are unable to register online, please email us at email info@closethegap.org.uk for assistance.
Three manifesto priorities for the 2026 Scottish Parliament election
Close the Gap has published its manifesto for the 2026 Scottish Parliament elections. We call for political parties to commit to action in three priority areas which are critical to women’s labour market equality:
- Build an economy that works for all women, including those who are most marginalised such as racially minoritised women, disabled women, young mothers and single parents.
- Reform the Scottish-specific duties of the public sector equality duty to ensure that the public sector leads the way on advancing women’s equality at work.
- Deliver a childcare system that centres gender equality and puts choice for all at the heart of provision.
Over time, we have seen some progress on women and work. But we also know that progress is fragile, as shown by Covid which resulted in a rolling back of women’s equality, and the cost of living crisis which hit women hardest. Globally we are seeing a backlash against equality, diversity and inclusion. Scotland is not immune to this, with rising misogyny, racism and right-wing activism threatening women’s equality and rights. In this volatile political context, it is imperative that political parties prioritise gender equality and make sure that tackling women’s poverty and inequality is centred in policy ambitions.
Our manifesto sets out 11 key asks which will make meaningful change for women in Scotland, including:
- Design and deliver targeted employability support for disabled women that is accessible, flexible, appropriate to skill level, and proactively challenges occupational segregation.
- Commit to using sectoral bargaining to improve and set pay, terms and conditions in the social care sector in 2026.
- Require public bodies to develop and report on gender pay gap action plans.
- Use state wage-setting powers to increase the pay of all childcare workers to the Real Living Wage, with a more ambitious target set thereafter.
Now is the time for parties to commit to a progressive agenda which ensures that the inequalities that shape the lives of women will be tackled. Our calls are informed by evidence of what will make a difference for women. The next Scottish Government must act decisively to turn evidence into action, ensuring that women’s equality is protected, progressed, and central to building a fairer Scotland for everyone.
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