Gender Pay Gap Action Plans: A Guide for UK CHROs
A credible gender pay gap action plan takes more than good intentions. Here’s how to build one that earns trust and stands up to scrutiny.
For years, UK employers have published their gender pay gaps for employees, candidates, and the public to see.
Starting in spring 2027, they'll also have to show what they're doing to fix it.
In a gender pay gap action plan, employers will be expected to explain:
A new law, subject to secondary legislation, requires UK employers with 250 or more employees to publish gender pay gap action plans alongside their annual reporting.
- Where pay gaps exist
- What they’re doing to address them
- How they’ll measure progress over time
Some organisations will treat the action plan as another compliance exercise. They’ll write down a few commitments, publish them alongside the numbers, and move on.
That could be a costly mistake.
Action plans will be open to scrutiny from employees, candidates, and the wider public. And people will be able to judge whether the actions promised are likely to make a meaningful difference.
At a Glance
Situation
Gender pay gap action plans will become mandatory for most UK organisations, subject to legislation.
Challenge
Employees and candidates will be able to judge whether those plans feel credible or superficial.
Opportunity
Use the requirement to make meaningful progress on gender pay gaps while building trust with employees and candidates.
“That creates reputational risk if they’re seen as weak or superficial,” says Claire Field, a UK-based pay equity expert and senior client partner at Korn Ferry.
What will make an action plan credible? Good intentions won’t be enough.
Employers will need to show that their actions address the right problems, explain why they chose them, and set measurable goals to track progress.
What Should Your Gender Pay Gap Action Plan Commit To?
Current government guidance provides 18 recommended actions for employers to choose from. Employers must select at least two: one to address their gender pay gap and one to support employees experiencing menopause.
“The danger for organisations, particularly if they haven't really gone here before, is they look at the list and choose two that seem easy,” says Field.
Going too far creates a different problem. Employers should avoid committing to more than they can realistically manage and deliver.
The right level will depend on where gender gaps are coming from. Organisations new to this process should start by identifying where those gaps emerge across the employee lifecycle, from recruitment and pay decisions to career progression and retention.
Expectations around pay transparency also continue to grow. While the UK’s gender pay gap action plans are separate from the EU Pay Transparency Directive, Field says developments elsewhere in Europe are changing how employees feel in the UK.
“It’s creating a tidal wave of expectations,” she says.
“Gender pay gap reporting is becoming more closely tied to employer brand, talent attraction, and overall corporate reputation.” Claire Field, senior client partner, Korn Ferry
Rather than trying to tackle every issue at once, Field advises focusing on a small number of priorities that you can realistically deliver and explain to others.
How to Build a Gender Pay Gap Action Plan
There isn't a single blueprint for a gender pay gap action plan. But the strongest plans tend to have several things in common. Field recommends focusing on the following eight areas.
1. Run Diagnostics to Identify Pay Gaps
This will help you understand potential problem areas, such as:
- Starting salaries
- Access to stretch assignments
- Off-cycle pay increases
- Promotion rates
- Career progression across different groups
Identifying where pay and career gaps emerge helps you see what’s holding people back and where action could make the biggest difference.
For example, Field worked with a CHRO who believed flexible working was supporting women's careers. But the data told a different story.
Employees who had flexible arrangements were far less likely to be offered high-profile projects or leadership opportunities. That insight helped the organisation reassess their people to see who might be best suited for career progression, regardless of their flexible working situation.
2. Establish What's Most Urgent and Meaningful
Meeting the minimum requirement is one thing. Trying to tackle every issue at once is another. Both approaches can undermine progress.
Focus on a small number of targeted actions, which are more likely to deliver meaningful change. A long list of commitments will be more difficult to sustain and measure.
3. Select Initiatives to Match Your Priorities
A mentoring programme, for example, won't solve a problem rooted in starting salaries. The actions you choose should reflect the issues your data uncovers.
Understand what’s behind your gender pay gaps and work out the most meaningful way of addressing them.
Start by asking two questions:
- What are we trying to change?
- How will we know if we've changed it?
4. Determine Measurable Outcomes
Decide how you'll measure progress within a year as well as over several years. But make sure you will see both short-term and long-term wins.
Some initiatives will make change happen quickly. Others will be bigger picture and take three or four years to materialise.
A mix of short-term and long-term goals helps maintain momentum while recognising that lasting change takes time.
5. Appoint Accountability
Every action should have a named executive owner. Accountability means someone is responsible for driving progress, removing barriers, and reporting on results.
6. Ensure You Have a Credible Pay Control Framework
A clear pay framework helps organisations make and explain pay decisions fairly and consistently. It can also reveal where informal practices, such as off-cycle pay increases, may be contributing to gender pay gaps.
For example, Field recently worked with a company where a review of discretionary pay found women were consistently less likely to receive off-cycle salary increases and retention awards.
The company introduced clearer approval criteria and documented the reasons for exceptional payments, creating a more consistent process for making those decisions.
7. Communicate Clearly and Meaningfully
You’ve got the plan in place. Now it’s time to tell people—to set and manage expectations around how you’ve landed on your goals, what you hope they’ll see soon, and what may take longer.
You also want to be transparent around how you’re going to measure success.
Tailor the message to your audience. Employees, senior leaders, and the public will all want different levels of detail.
But they'll all expect clarity about what the organisation is trying to achieve and how progress will be measured.
8. Be Prepared to Adapt as Things Change
An action plan shouldn't be treated as a static document.
As workforce data changes and new employee feedback emerges, organisations should review whether their priorities are still the right ones for the business. Add in regular sense-checks to review and update the plan.
3 Questions Before You Publish Your Action Plan
1. Would these actions still be our priorities if we weren't required to publish them?
If the answer is no, you're probably treating the exercise as compliance rather than solving the workforce issues behind your pay gap. That could leave you with actions that make little difference and a public plan that’s difficult to defend.
2. Can we show how we'll measure progress?
Broad commitments are easy to publish. Credible action plans explain what success looks like and how it will be tracked over time.
3. Could we explain these decisions to our employees?
Employees don't expect organisations to solve every issue immediately. They do expect to understand why certain actions have been prioritised and how they'll make a difference.
Pay Equity Starts with Transparency
No organisation can solve pay gaps overnight. Simply showing you know where gaps exist and that you’re taking meaningful action will go a long way with employees and candidates.
That work starts with understanding whether the systems behind pay decisions are consistent and fair. That's where pay transparency becomes an important part of the equity conversation.
Put Pay Transparency into Action
Clearer pay practices can strengthen trust and support more consistent decisions. Read our guide to building a practical approach to pay transparency.
