17.1. Currently large employers, i.e. employers with 250 or more employees must publish annual gender pay gap reports.
17.2. The Employment Rights Act expands this by requiring large employers to publish “Equality Action Plans” which detail what actions they are taking to improve gender equality, including reducing the gender pay gap. Any company which an employer outsources work to should be included in the Equality Action Plan. The idea is that this will encourage the employer to ensure that the companies it contracts with are also taking steps to support gender equality.
17.3. From Spring 2026 employers can voluntarily publish Equality Action Plans which will become compulsory from Spring 2027. However information relating to outsourcing is subject to broader pay gap reforms and does not currently have an implementation date.
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