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.