Publishing your gender pay gap (GPG) data is just the beginning. Organisations that publish only the bare minimum—with no explanation or action plan—often face more scrutiny than those with a larger gap who communicate openly about it.
The narrative is your chance to show the story behind the numbers. The gender pay gap action plan is where you show what you’re actually doing about it. Together, they’re your opportunity to demonstrate to employees, candidates, and stakeholders that your organisation takes this seriously.
What is a gender pay gap narrative?
A gender pay gap narrative accompanies your report. It is a written explanation of your figures, providing the context and causes behind them.
It’s a chance to not just reiterate the numbers you’ve provided, but to uncover the trends and structures in your business that contribute to them—foregrounding your action plan that provides your next steps.
What is a gender pay gap action plan?
A gender pay gap action plan is a structured set of commitments designed to address the underlying causes of your organisation’s gender pay gap. While UK regulations require eligible employers to publish gender pay gap data, they don’t mandate a formal action plan. However, stakeholders increasingly expect employers to explain what their figures mean and outline measurable steps to reduce structural differences.
An effective action plan links directly to your reported data, sets time-bound objectives, and assigns clear ownership at senior level.
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How to write a gender pay gap action plan and narrative
So, what do you need to include in a gender pay gap narrative and action plan? Here’s all you need to know:
Do you have to write a narrative?
No—a narrative and action plan aren’t legally required for most private and voluntary sector employers.
If your gap has widened year-on-year, or your figures are significantly above your sector average, publishing without any context is a reputational risk in itself. Silence tends to invite more questions, not fewer.
Although not legally required for most private and voluntary sector employers under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, action plans are increasingly viewed as best practice. Investors, procurement frameworks, and ESG assessors often look beyond the headline percentage to assess whether organisations are taking credible steps to improve representation and progression outcomes.
What to include in your gender pay gap narrative
A strong gender pay gap narrative typically covers four things:
Context for your figures
This is your chance to explain what’s driving your numbers—so don’t just restate them. Is the gap primarily a representation issue at senior levels? Do you have a large proportion of part-time roles concentrated in one gender? Are there particular business units creating a skew? The more specific and honest you are, the more credible your narrative becomes.
Year-on-year comparison
If your gap has improved, say so—and explain what contributed to it. If it’s widened, acknowledge it and explain why, whether that’s a structural change, an acquisition, or a recruitment spike in a particular area.
Trying to obscure a worsening gap rarely works; honesty really is the best policy here.
What you’ve already done
Document the actions you’ve taken in the previous reporting period—and be specific. “We introduced structured interview panels” is more credible than “we are committed to inclusive hiring”. Specificity builds trust.
What you’re planning to do
Lead into your action plan here. This creates a natural bridge between your narrative and the commitments you’re making for the year ahead—and it shows you’ve thought beyond just the numbers.
What to include in your gender pay gap action plan
Your action plan should be concrete, time-bound, and realistic. A credible plan typically includes:
- Specific actions with named owners or responsible teams, not just broad intentions
- Target timelines with actual dates
- Measurable outcomes wherever possible: for example, targeting a specific percentage increase in women in senior leadership by a defined date
- A mix of short and longer-term commitments: some things you can do now (reviewing job description language, for instance) and some that will take longer (building a pipeline of senior female talent)
Common gender pay gap action plan themes include pay and grading reviews, flexible working improvements, mentoring and sponsorship programmes, inclusive recruitment practices, and returner programmes for people coming back from career breaks.
One important note: keep your narrative honest and human, not defensive or corporate. And be careful with language—avoid phrasing that inadvertently suggests unlawful pay practices when the actual issue is structural representation.
Six ways to reduce your gender pay gap
1. Assess your current situation properly
You can’t fix what you don’t understand. Start by analysing your pay data properly—not just the headline figures, but the detail underneath them.
Look at:
- Where the gap exists: is it concentrated in certain departments or levels?
- Like-for-like comparisons: are people in similar roles being paid the same, regardless of gender?
- Progression patterns: are women moving through your organisation at the same rate as men?
- Starting salaries: are you offering the same starting pay to men and women in the same roles?
This kind of analysis often reveals that the gap isn’t evenly spread—it tends to cluster in specific areas. That’s useful, because it helps you focus your actions where they’ll have the most impact.
2. Review your recruitment and promotion processes
This is where unconscious bias can sometimes creep in, and it’s not always obvious until you look closely. Ask yourself:
- Are job descriptions using gendered language that might put off certain candidates?
- Are you interviewing a diverse pool of candidates for senior roles?
- Do your promotion criteria favour people who’ve had uninterrupted career progression (which often disadvantages women)?
- Are decisions being made by diverse panels so unconscious bias can’t creep in?
Small changes here—like using gender-neutral language in job ads or using structured interview scoring—can make a real difference over time.
3. Offer equal opportunities for career development
Make sure both male and female employees have access to the same training, mentorship, and advancement opportunities. In practice, this means:
- Formal development programmes, not just informal mentoring that tends to favour people who look like the existing leadership, but structured and documented training for everyone.
- Clear progression pathways that are documented, giving a route to move up so everyone knows what’s required—not just the people who happen to have the right conversations.
- Sponsorship programmes where senior leaders actively champion talented people from underrepresented groups.
4. Offer flexible working arrangements
Flexible working isn’t just about working from home (though that helps). It’s about giving people real options that help them balance work with caring responsibilities—which disproportionately affect women.
Consider:
- Part-time options at all levels, including senior roles
- Term-time working, particularly valuable for parents
- Compressed hours, like four-day working weeks, that allow full-time hours over fewer days
These options need to be genuinely accessible—not just technically available. If every senior role quietly requires 60-hour weeks in the office, flexible working exists in name only.
5. Implement pay transparency
Being open about your pay structures helps maintain fairness and shows your people you’re serious about addressing the gap. That doesn’t mean publishing everyone’s salary—but it might mean:
- Clear pay bands so people know what roles at different levels should pay
- Transparent criteria so it’s clear how pay decisions are made
- Regular reviews to check for unexplained disparities and allow for open conversations about pay progression
6. Review bonus and performance calibration processes
In many organisations, discretionary bonuses and performance ratings amplify pay gaps more than base salary does. Review how performance is assessed and calibrated across teams.
Ask:
- Are performance scores evenly distributed by gender?
- Are discretionary bonuses applied consistently?
- Are revenue-generating roles, which attract higher bonuses, gender-balanced?
Even small inconsistencies in bonus allocation can significantly widen your reported mean and median gaps.
Common pitfalls to avoid
As you work through your reporting, here are the mistakes that come up most often:
- Confusing the gender pay gap with equal pay; they’re different things. You can have a GPG even if you’re paying people equally for the same work.
- Only looking at the numbers once a year, after all, your snapshot date is just that—a snapshot. Monitoring your GPG throughout the year means you can spot trends early and act on them proactively.
- Publishing data without context—your numbers tell part of the story, not all of it. A narrative explaining your figures (and what you’re doing about them) is always worth including.
- Focusing only on recruitment. If women aren’t progressing once they’re in your organisation, recruitment alone won’t close the gap.
- Treating it as an HR issue alone; this needs genuine leadership buy-in and action across the whole organisation.
Intersectionality and voluntary reporting beyond gender
The gender pay gap doesn’t exist in isolation. For a lot of employees, pay and progression outcomes are shaped by several characteristics—gender, ethnicity, disability, age, and socioeconomic background. Reporting only on gender gives you an incomplete picture.
Ethnicity pay gap reporting
Ethnicity pay gap reporting isn’t yet a legal requirement in the UK, but it’s been subject to ongoing government consultation and is widely expected to become mandatory for larger employers in the coming years. A lot of organisations are choosing to report voluntarily now—both to stay ahead of likely legislation and to show a genuine commitment to equity beyond gender.
Disability pay gap reporting
Similarly, disability pay gap reporting isn’t currently mandatory, but it’s an area of growing expectation. The disability pay gap in the UK is significant— disabled employees earned a median £13.69 per hour (ONS). This is 12.7% less than non-disabled workers on average. Organisations with strong equity, diversity, and inclusivity (EDI) credentials are increasingly expected to understand and address it.
Why this matters for your gender pay gap
Intersectional data often reveals that headline GPG figures mask significant variation within gender groups. A woman who is also from an ethnic minority background, or who has a disability, may face compounding disadvantages that a gender-only analysis simply doesn’t capture. Organisations that take intersectionality seriously tend to design more effective interventions because they’re targeting the right groups with the right actions.
What to do now
Even if you’re not ready to publish intersectional data, there are practical steps you can take:
- Review last year’s gender pay gap movement and identify the primary driver (representation, bonus allocation, recruitment, or progression).
- Assign executive ownership for each action within your plan.
- Set measurable 12-month targets, even if they are modest.
- Review bonus and promotion decisions before your next snapshot date to prevent unintended widening of the gap.
- Improve diversity data collection to enable more accurate internal analysis.
Why leadership ownership matters
Gender pay gap reporting is not solely an HR responsibility. The named director who signs the report carries formal accountability, and stakeholders increasingly expect visible leadership involvement.
Organisations that reduce their gender pay gap sustainably tend to share three characteristics:
- Board-level sponsorship
- Clear accountability for delivery
- Regular progress reporting beyond the annual snapshot
Without senior ownership, gender pay gap action plans often remain aspirational rather than operational.
Take control of your gender pay gap action plan & narrative
GPG reporting might feel like another compliance task to tick off the list. But done well, it’s so much more than that. It’s a genuine chance to understand what’s really happening in your organisation—and to have honest conversations about pay, progression, and fairness.
Whether you’re writing your first action plan or your tenth, the goal is the same: make it specific, honest, and something your employees, candidates, and stakeholders can actually believe in.
If you’d like to see how Cintra can support your gender pay gap reporting—including keeping an eye on your data throughout the year, not just at snapshot time—we’d be happy to walk you through it.
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