These requirements apply to businesses with 250 or more employees on a specific ‘snapshot date’ each year (5 April for private sector businesses, and 31 March for most public sector organisations), the same threshold as existing gender pay gap reporting.

Here the definition of “employee” for gender pay gap reporting is broader than the standard employment law definition. So anyone with an employment contract, including full-time, part-time, fixed-term or zero-hours contract employees, agency workers (if they are on your payroll), workers and apprentices, all count towards the threshold. But genuinely self-employed freelancers do not count towards the threshold.

Smaller businesses (with under 250 employees) are encouraged but not required to publish action plans.

Current position (since 2017): Larger businesses must publish gender pay gap data annually, showing the difference in average pay between male and female employees. This is data reporting only, so there is no requirement to explain the gap or commit to reducing it.

Since April 2026 (voluntary): Businesses can voluntarily publish action plans alongside their gender pay gap data, showing a) the steps they are taking to reduce their gender pay gap, and b) how they are supporting employees through the menopause.

From spring 2027 (mandatory, subject to legislation): These action plans become a legal requirement. Larger businesses must publish both their data and their action plans.

An action plan must set out what the business is doing on both its gender pay gap and menopause support. The government does not fix a minimum number of actions, but its published list of recommended, evidence-based actions for the gender pay gap includes:

• reviewing recruitment and promotion practices,
• increasing transparency around pay, promotion and rewards,
• offering mentoring, sponsorship and development programmes,
• enhancing and promoting flexible working policies, and
• encouraging employee development through actionable feedback.

To support employees experiencing the menopause, the recommended actions include:

• training managers to support employees experiencing the menopause (including understanding symptoms, the law, how to encourage employees to raise concerns, and what adjustments could be made),
• offering occupational health advice for employees experiencing the menopause, and
• offering workplace adjustments (flexible working hours, access to private rest areas, ergonomic furniture, and environmental settings like temperature control).

The government notes that although the menopause typically occurs between ages 45 and 55, perimenopause can begin earlier, so support should be accessible to employees of different ages. Actions may also benefit employees with related health conditions like endometriosis, fibroids or PCOS.

Action plans must be submitted and published on the gender pay gap reporting service website, where they will be publicly available alongside the pay gap data. Of course a business can also publish them on its own website.

Screen industries have well-documented gender imbalances, particularly in senior creative and technical roles. Contributing factors include:

• Women underrepresented in senior roles (directors, heads of department, execs),
• Concentration of women in lower-paid admin or junior roles,
• Career breaks for caring responsibilities disproportionately affecting women’s progression,
• A long-hours culture with inflexible working patterns (location shoots, late-night filming) creating barriers for those with caring responsibilities, and
• Lack of transparent pay structures or negotiated deals creating disparities.

It’s worth noting that menopause is not a protected characteristic under the Equality Act 2010, and the new action plans do not change that. But employees experiencing menopause symptoms may already be protected from discrimination under sex discrimination (since the menopause only affects women), age discrimination (since the menopause typically affects women in a particular age range) and disability discrimination (because, if menopause symptoms have a long-term and substantial impact on the ability to carry out normal day-to-day activities, this could be a disability requiring reasonable adjustments). Tribunals have upheld claims in recent years where menopause-related issues were dismissed or mishandled.

Count your employees (as defined above) on the relevant snapshot date. If you are at or near 250, you will need action plans from spring 2027. Even if you are below 250, consider whether your workforce is growing.

You can publish a voluntary action plan now. This gives you time to understand the process, analyse your data, identify the causes of your pay gap, talk to employees about what actions would be most impactful, and test your approach before it becomes mandatory.

By “analyse your data” we mean not just reporting the gender pay gap but understanding what is causing it. Where are women concentrated in your business (roles, levels, departments)? Are they represented in senior positions? What are your promotion rates by gender? Examine part-time working patterns (women are more likely to work part-time) and where your organisation is losing women.

Speak to women in your organisation about the barriers they face to progression, what adjustments would make the biggest difference, and whether menopause support is adequate (or exists at all).

Specific, measurable and meaningful actions for screen businesses might include:

• By December 2027, introducing flexible working as the default for all office-based roles, with remote options for post-production staff,
• Implementing blind recruitment for all roles from April 2027, removing names and gender indicators from initial application reviews, and
• Ensuring all line managers complete menopause awareness training by September 2027, alongside a menopause support policy that includes reasonable workplace adjustments.

Action plans that are just HR tick-boxes will not produce change. Senior leadership buy-in, proper budget allocation and detailed accountability (who is responsible for delivering each action?) are key.

Please also be aware of the “compliance risk”. Once you have published your action plan it becomes a public commitment. Be ambitious but realistic, and do not over-promise. Failing to deliver what you promised could become evidence against you in equal pay claims, sex discrimination claims or menopause-related discrimination claims (which can be brought under sex, age or disability discrimination law).