These requirements will 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’re on your payroll), workers, apprentices, all count towards the threshold. But genuinely self-employed freelancers don’t count toward the threshold. 

Smaller businesses (with under 250 employees) will be 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’s no requirement to explain the gap or commit to reducing it. 

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

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

Action plans must include at least one action to reduce your gender pay gap.

The government’s published list of recommended, evidence-based actions 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. 

And at least one action to support employees experiencing menopause, such as: 

• Training managers to support employees experiencing 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 menopause, and 

• Offering workplace adjustments (flexible working hours, access to private rest areas, ergonomic furniture, environmental settings like temperature control). 

The government notes that although menopause typically occurs between ages 45-55, 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’ll 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, HoDs, 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 don’t change that. But employees experiencing menopause symptoms may already be protected from discrimination under sex discrimination (since menopause only affects women), age discrimination (since menopause typically affects women in a particular age range) and disability discrimination (because if menopause symptoms have a long-term and substantial impact on 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’re at or near 250, you’ll need action plans from 2027. Even if you’re below 250, consider whether your workforce is growing. 

From April 2026, you can voluntarily publish an action plan. This gives you a year to understand the process, analyse your data, identify 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’s 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. 

It may sound obvious but 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 if it exists at all). 

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

• By December 2027, we’ll introduce flexible working as the default for all office-based roles, with remote options for post-production staff, 

• We’ll implement blind recruitment for all roles from April 2027, removing names and gender indicators from initial application reviews, 

• All line managers will complete menopause awareness training by September 2027, and we’ll establish a menopause support policy including reasonable workplace adjustments. 

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