Equal pay audit step 5: developing an action plan

Multipage Guide

Who is this page for?

  • large organisations (50 or more employees)

Which countries is it relevant to?

    • Great Britain

Putting an action plan in place

What happens next in your equal pay audit depends on whether or not you found any pay differences for which there was no satisfactory explanation and justification.

If you have found differences in pay which cannot be justified, you must put a plan in place to address this as soon as possible. It may not be possible to implement equal pay immediately, but your action plan should set out when and how you will rectify pay issues, and why this is the soonest that it can be done. Set clear timescales and stick to them. Remember, delay could put you at increased risk of equal pay claims being made against you, and the longer you take to resolve any issues highlighted by the review, the greater the amount of back pay and compensation you might have to pay successful claimants. Where possible, it would be beneficial to involve any relevant trade unions in formulating the action plan. 

If you didn’t find any unjustified gender pay differences, your organisation will still benefit from continuing to review and monitor your pay policies and practices to maintain your current standards.

Developing an equal pay action plan

The specific actions you need to take will depend on the nature and extent of the pay differences you’ve identified and their causes.

As you worked through Step 4 of the audit, identifying the causes of the pay gaps, the actions required will probably have become clear, although not necessarily easy to implement.

At a basic level, your equal pay action plan should include arrangements to:

Provide equal pay

If your audit finds pay differences related to sex for which there is no justification, you must plan to provide equal pay for current and future employees as soon as is practicable. Liability for equal pay starts from the point at which a claim is submitted (with up to six years’ back pay). Your action plan should make your timescales clear and these must be over the short term.

Employee relations may also be important. Providing equal pay is likely to mean redistribution of the overall pay budget over a period of time to favour 'underpaid' employees. You may need to manage factors such as the possible dissatisfaction of employees who perceive a loss of status, or the erosion of differentials, while equal pay is being provided.

Change the pay policies and practices that contribute to unequal pay

Once your equal pay audit has identified the causes of unequal pay and shows that those causes are not justified, you must change any current pay policies and practices accordingly.

Examples of typical pay policies and practices which organisations have needed to change following equal pay audits include:
• starting salaries
• performance management systems
• market supplements
• pay protection, and
• eligibility for bonuses and allowances.

For further information see Risky practices.

Introduce an equal pay policy

Develop and publish an equal pay policy that commits your organisation to providing equal pay, with clear accountabilities, regular monitoring and adequate resources for equal pay audits. It should be an explicit equal pay policy, rather than something included within a more general equality and diversity policy.

For more detailed information to help you provide equal pay in your organisation, see How to achieve equal pay.

Last updated: 19 Feb 2019

Contact Acas for further information

If you are involved in an employment dispute or are seeking information on employment rights and rules, you can contact the Advisory, Conciliation and Arbitration Service (Acas):

Visit the Acas website

Freephone: 0300 123 1100 (8am to 8pm Monday to Friday and 9am to 1pm Saturday)

Text Relay service: 18001 0300 123 1100.