Equality Action Plans: An opportunity for systemic change

When the Employment Rights Bill introduced the concept of mandatory equality action plans (EAPs) for large employers, it felt like a pivotal moment: a shift towards evidence-based action on workplace equality.

Now that the Bill has become the Act, what can we expect – a seismic shift towards true equality… or a toothless tiger that will allow employers to signal virtue without driving real change? Time, and more importantly, the impending regulations that must be consulted on and put into place before EAPs become mandatory for large employers will tell, but here are some thoughts from PathLight.

‘Evidence-based actions for employers?

Last year, the Government Equalities Office published a toolkit on gender equality in the workplace, which included a research paper based on an analysis of multiple research papers published over the last decade on actions that employers could take to improve gender equality that would drive real change. The paper provides guidance on evidence-based actions for employers and sets out suggested practical interventions across recruitment, progression, pay, retention and leadership. It is not a huge leap to assume that this research paper (or an updated version of it) will form the basis of the Government’s list of evidence-based actions for employers when it comes to EAPs.

The research paper encourages employers to use data to understand where inequality arises across the employee lifecycle – from hiring and starting pay, through progression and performance, to retention and exits. Employers are encouraged to select interventions that address their specific drivers of inequality, and to review impact over time – all of which we at PathLight wholeheartedly (if rather biasedly, since this sensible, evidence-based thinking is the basis of our business!) support.

‘Effective actions’

So, what’s on the list? There are two categories of information: ‘effective’ actions and ‘promising’ actions.

Effective actions are given priority in the paper, which makes sense, because they are backed by evidence that shows they make real change. They include:

Hiring and selection

• Advertise flexible working by default, which significantly increases applications from women.

• Use structured interviews for recruitment and promotion to reduce bias and improve consistency.

• Publish salary ranges and clear negotiation parameters to reduce gender differences in starting pay.

Talent management, learning and development

• Increase transparency in pay, reward and promotion processes, so expectations and decision-making criteria are clear and consistently applied.

Inclusion and retention

• Normalise flexible working and parental leave by communicating what people actually do (not what people assume they do), and thereby encourage take-up across the board.

• Improve access to flexible working options (for example part-time, remote or hybrid working) and support senior leaders to champion and role-model their use.

Leadership and accountability

• Embed senior leadership accountability for gender equality outcomes, supported by regular reporting and oversight.

• Use data to monitor progress, ensuring equality actions are reviewed and adjusted based on measurable impact.

These are good, solid actions, all of which we have recommended to clients we have worked with when their specific situations required them. The ‘promising actions’ are similarly positive, but the Government is transparent that their impact needs further research (and so the ‘effective actions’ should be prioritised).

So far, so good. Yet there is a fundamental, structural problem with EAPs – and it is not the recommended actions.

A Toothless Tiger?

The deeply frustrating truth about EAPs is that although having a plan is compulsory, executing on it is not. An employer can, in theory, publish a technically compliant plan that lists actions from the recommended menu without really understanding the specific needs of their organisation, and without ever embedding the actions that they choose to list in their EAP into day-to-day decision-making, line management practice or organisational strategy. There is no mandatory obligation to operationalise, resource, execute or measure EAPs beyond publication. There are no statutory requirements for governance, delivery milestones, outcome metrics or consequences for failing to act on what has been promised.

This is a major gap.  Experience with the existing gender pay gap reporting regime suggests that transparency alone, without accountability for outcomes, has limited impact on deep-rooted structural inequality. Despite nearly a decade of reporting, progress in closing the gender pay gap has been slow and uneven, and many organisations still struggle to explain why their gaps exist, let alone how they will close them.

The government’s approach to EAPs appears to somewhat naively assume that once employers are nudged towards evidence-based actions, they will analyse their data, choose interventions thoughtfully, implement them consistently and measure progress year on year. It is a hopeful assumption – but not one strongly supported by recent history.

Without clear expectations around execution and impact measurement, EAPs risk becoming a toothless tiger: highly visible, symbolically important, but ultimately unable to shift the systems and structures that drive inequality in the first place.

So what?

This matters because the barriers these plans are intended to address are rarely simple or isolated. Gender (or any other workplace) inequality is not confined to one life stage or one policy gap. It accumulates over time, shaped by recruitment practices, informal networks, progression norms, flexibility assumptions and organisational design.

There is, however, a real opportunity here. Done well, Equality Action Plans could provide businesses with a structured moment to step back and interrogate the systems and assumptions that quietly shape who progresses, who is rewarded and who leaves. They could act as a catalyst to dismantle outdated workplace structures that were never designed for today’s workforce, and which continue to drive inequality in pay, progression and opportunity. However, without stronger expectations around execution and impact, there is a danger that organisations invest time and money in producing EAPs that look impressive on paper, but leave the underlying barriers that they are intended to reduce or remove firmly in place.

If EAPs are to deliver meaningful change, they need to move beyond planning and into execution. That means grounding actions in robust data, embedding them into core business processes, assigning clear accountability and measuring impact rigorously.

At PathLight Inclusion Solutions, this is what we do: the core of our business is to support employers to understand where inequality arises in their workforce, to design interventions grounded in evidence and data, and to embed those interventions into the way work actually gets done.  We know that this approach works and that it can change things for the better – but it requires real buy in from leaders, time, money and commitment. The government guidance provides a useful starting point, but without mandatory requirements to implement and evaluate equality action plans, the risk remains that all this will do is add another reporting layer for businesses without delivering better outcomes for employees.

Equality Action Plans have the potential to be a powerful lever for change, but only if they are grounded in data, embedded into how organisations actually operate, and regularly measured to ensure effectiveness. Otherwise, they risk becoming highly visible statements of virtuous intent with little impact. The question for employers as we go into voluntary compliance in 2026 and mandatory compliance in 2027 is where do you stand?  Are you going to spend time and resources creating a virtue signalling plan that you never intend to follow?  Or are you actually going to commit to making positive change for large swathes of your talent?

We’re Pathlight Inclusion Solutions – we help forward thinking businesses to understand where they stand on inclusion and workplace fairness now, and to build a strategic plan for the future.  Come and say hi!  www.path-light.io; Hello@Path-Light.io