An equality and diversity policy is a written statement of how an organisation treats people fairly, prevents discrimination, and values difference. It is the document that sets expectations for staff and managers, explains how to raise concerns, and provides the framework for everything from recruitment through to disciplinary action.

This guide explains what should go into one, what's changed in the law since 2024, and gives you a template structure to adapt. It's relevant whether you're a small business writing your first policy, a charity updating an old one, or an HR manager who's inherited a policy that hasn't been touched since 2018.

Is an equality and diversity policy legally required?

In England, Scotland and Wales an equality and diversity policy is not itself legally required. What the law requires is compliance with the Equality Act 2010 — that you don't discriminate, harass or victimise people because of a protected characteristic, that you make reasonable adjustments for disabled people, that you take active steps to prevent sexual harassment, and (if you're a public body) that you have due regard to the Public Sector Equality Duty.

A policy is the most common way of evidencing that you take those duties seriously and have a coherent approach to them. The Equality and Human Rights Commission recommends that every organisation has one. Employment tribunals routinely look at whether an employer had a policy, whether it was communicated to staff, and whether it was followed when assessing claims.

Separate gender pay-gap reporting requirements apply to employers within the relevant regulations. The 250-employee threshold applies to private and voluntary-sector reporting and specified English public authorities; devolved public-sector duties differ. The policy should describe the obligations that actually apply to the organisation.

What to include

The following ten areas provide a practical structure to adapt to the organisation. They are guidance, not a statutory checklist.

The ten sections an equality and diversity policy should contain

1. Purpose and scope

What the policy is for and who it applies to. Scope usually covers employees, workers, contractors, volunteers, agency staff and job applicants. Some organisations also extend the policy explicitly to customers, service users and the public — useful both for legal cover and for cultural clarity.

2. Legal framework

A short reference to the Equality Act 2010, the nine protected characteristics, the duty to make reasonable adjustments, and the prohibitions on direct discrimination, indirect discrimination, harassment and victimisation. Public sector employers should also reference the Public Sector Equality Duty.

3. The organisation's commitments

What the organisation actually commits to do. This isn't a place for vague aspirations. Specific commitments work better: 'we will publish our gender pay gap annually', 'we will offer reasonable adjustments at recruitment and during employment', 'we will train all managers on inclusive recruitment', 'we will provide mandatory equality training during induction and refresh it every two years'.

4. What is prohibited

Direct and indirect discrimination, harassment (including sexual harassment and third-party harassment), victimisation, and bullying. State the consequences plainly.

5. Roles and responsibilities

What managers are expected to do (model the policy, respond to concerns, accommodate reasonable adjustments), what HR is expected to do (advise, investigate, monitor), what every employee is expected to do (read and follow the policy, raise concerns). The board or senior leadership should be named as accountable.

6. Recruitment, selection, pay and progression

Fair adverts, fair selection criteria, blind shortlisting where practicable, structured interviews, pay decisions based on objective criteria, promotion based on capability. This section is the part of the policy with the most legal exposure.

7. Reasonable adjustments

A clear statement that the organisation will make reasonable adjustments for disabled employees and job applicants, how to request them, and the process for assessing and providing them. Reference our fuller guide to reasonable adjustments under the Equality Act.

8. Harassment and complaints

How to report harassment or discrimination, including the option to raise concerns informally and the formal grievance route. The Worker Protection Act 2023 has reshaped what good practice looks like here — see below.

9. Monitoring and data

Explain what monitoring data is collected, why, its Article 6 lawful basis under UK GDPR and, where special-category information is involved, the additional Article 9 condition and any applicable Data Protection Act 2018 safeguards.

10. Review

A commitment to review the policy regularly — annually is the usual standard — and to update it after material legal changes or significant organisational change.

Sample template wording

The structure below is a starting point. Replace bracketed text and adapt to your sector and size.

Purpose and scope

[Organisation name] is committed to providing equal opportunities and to a workplace free from unlawful discrimination, harassment and victimisation. This policy applies to all employees, workers, contractors, volunteers, agency staff and job applicants, and to the services we provide to our customers and the public.

Legal framework

This policy is informed by the Equality Act 2010, which prohibits discrimination on the grounds of nine protected characteristics: age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. [If applicable: We are also subject to the Public Sector Equality Duty under section 149 of the Act.] We also recognise our duties under the Worker Protection (Amendment of Equality Act 2010) Act 2023 to prevent sexual harassment, and we are reviewing our practices in advance of further changes taking effect in October 2026 under the Employment Rights Act 2025.

Our commitments

We will: provide equality, fairness and respect for all staff; make reasonable adjustments for disabled employees and applicants; provide training on equality and diversity at induction and as part of ongoing development; investigate complaints of discrimination, harassment and victimisation; review pay annually and publish our gender pay gap data [if 250+ employees]; monitor the diversity of our workforce and act on what the data shows; and review this policy annually.

What is prohibited

Direct discrimination, indirect discrimination, harassment (including sexual harassment and harassment by third parties), victimisation, and bullying. Breach of this policy will be treated as a serious disciplinary matter, up to and including dismissal.

Responsibilities

[Senior named role] is responsible for the implementation of this policy. All managers are responsible for modelling its expectations and responding to concerns. All employees are responsible for treating colleagues, customers and the public fairly and for raising concerns through the appropriate route.

Reasonable adjustments

We will make reasonable adjustments for disabled employees and job applicants. Requests can be made to [named contact] at any point and will be discussed openly. We do not require a formal diagnosis before considering an adjustment.

Raising concerns

Anyone affected by behaviour that falls below the standards in this policy can raise it informally with their manager, with [HR contact], or formally under our grievance procedure. Where the matter involves harassment or potential criminal conduct, the formal route is usually appropriate.

Monitoring

We collect equality monitoring information for [specific purpose]. Participation is voluntary. Our Article 6 lawful basis is [appropriate basis]; for special-category data our Article 9 condition is [appropriate condition], with any required Data Protection Act 2018 safeguards and policy document. We restrict access, explain retention and publish results in a form that protects individuals. [Adapt this wording to the actual process before use.]

Review

This policy will be reviewed annually and updated whenever material legal or organisational changes occur.

Adapt the language to the sector and jurisdiction. For example, an English care provider may need to reference the Care Act 2014, while public authorities should identify their applicable equality duties and objectives.

What's changed since 2024

Two developments are reshaping what counts as a good policy. Both should be reflected in any policy written or revised from late 2024 onwards.

Since 26 October 2024, section 40A of the Equality Act requires employers in Great Britain to take reasonable steps to prevent sexual harassment of workers. Where a sexual-harassment claim succeeds and the preventative duty was breached, a tribunal can increase compensation by up to 25%.

From 30 October 2026, the standard is due to become “all reasonable steps”, with additional third-party harassment provisions. These changes are still future on this guide’s 15 October review date. The statutory harassment provisions do not cover all nine characteristics identically; marriage/civil partnership and pregnancy/maternity are not relevant characteristics under section 26, although other protections may apply.

Recruitment, selection and pay

Recruitment, selection and pay decisions should be covered clearly because they can create discrimination risks.

For recruitment: write job descriptions in plain English, list essential and desirable criteria separately, advertise in at least two channels to reach a wider audience, train shortlisters in inclusive practice, and use structured interviews with the same questions for every candidate. Make reasonable adjustments at every stage from application to interview to assessment.

For pay, review decisions against objective criteria and investigate unexplained differences. Equality Act equal-pay provisions concern sex equality in contractual terms. Other discriminatory pay treatment can fall under the Act’s discrimination provisions; direct discrimination cannot generally be justified merely by citing a business reason.

For progression: training opportunities should be open and known, succession planning should be transparent, and high-potential or talent schemes should be assessed for whether they reproduce the existing demographic mix of senior roles.

Embedding the policy

A written policy is the foundation, not the building. Training, monitoring and routine reinforcement are what make it real.

Training should be mandatory at induction, refreshed periodically, and tailored to role — managers need more detail on their specific responsibilities, including the duty to make reasonable adjustments and to prevent harassment.

Monitoring should be regular, voluntary and anonymised, with results reviewed at leadership level and acted on where patterns emerge.

Reinforcement happens in the small day-to-day decisions. A policy that says 'we welcome applications from candidates with disabilities' followed by an inaccessible interview venue is doing harm. The signal is the action, not the document.

Data protection and monitoring

Some equality monitoring information is special-category data, including ethnicity, religion, sexual orientation and health information. Age and sex are not themselves special categories; gender identity is not automatically one, although information revealing health or another listed category may qualify. Identify both an Article 6 lawful basis and, where needed, an Article 9 condition. Consent in employment requires particular care because it must be freely given.

Practically, this means: collect voluntarily, explain why you're collecting, separate the monitoring data from personnel records, restrict access, and don't use individual responses in management decisions.

Policies most templates miss

Three areas are increasingly expected in modern UK policies and are missing from most older templates.

Key provisions most equality and diversity policy templates miss

Third-party harassment

Following the Employment Rights Act 2025, the harassment section needs to address harassment by customers, contractors and members of the public, not just colleague-on-colleague. Policies should describe how staff should respond, how managers should act, and what the organisation will do.

Neurodivergence

Specific provision for neurodivergent staff — autism, ADHD, dyslexia, dyspraxia and related conditions — is increasingly expected. Reference our guide to neurodiversity in the workplace for context.

Menopause, fertility treatment and pregnancy loss

All three are increasingly addressed in mainstream policies, partly because case law in these areas has been developing and partly because organisations have realised that not addressing them causes good people to leave.

Reviewing the policy

A planned annual review can be useful, alongside reviews after significant legal or organisational changes or serious incidents. There is no universal Equality Act rule prescribing an annual policy review. Check the precise commencement dates of changes, including those due on 30 October 2026.

The review should look at the policy text, but also at whether the policy is working in practice. Are reasonable adjustment requests being made? How are they being handled? What does the monitoring data show? Are complaints being raised, and what's happening to them?

Frequently asked questions

Is an equality and diversity policy legally required?

In England, Scotland and Wales, an EDI policy is not directly required by the Equality Act 2010. However, the Act creates duties that a policy is the most practical way of meeting, and the EHRC recommends that every organisation has one.

What should be in an equality and diversity policy?

Purpose and scope, legal framework, the organisation's specific commitments, what is prohibited, roles and responsibilities, recruitment and pay, reasonable adjustments, harassment and complaints procedures, monitoring and data, and review arrangements.

How often should I review the policy?

An annual review is a practical recommendation, not a universal statutory interval. Review sooner when relevant law, working practices or evidence of problems changes.

Do I need a separate harassment policy?

Not necessarily. Many organisations integrate harassment into their equality and diversity policy; others have a separate, more detailed harassment and bullying policy. The choice often depends on size — larger employers tend to have separate policies for clearer signalling.

Can I collect diversity data on my staff?

Yes, with a valid Article 6 lawful basis and, for special-category information, an additional Article 9 condition and relevant safeguards. Not every diversity field is special-category data. Explain the purpose, protect confidentiality and avoid identifying individuals in published small groups.

What size of business needs an EDI policy?

Any size. The legal duties under the Equality Act apply to all employers regardless of headcount. Small employers might have a shorter, simpler policy, but the absence of one is increasingly noticed by customers, funders and prospective employees.

An equality and diversity policy works best as part of a wider framework that includes the Equality Act 2010 it sits under, the workplace framing of equality, diversity and inclusion, and (for public bodies) the Public Sector Equality Duty. To get your staff trained on the policy and the duties it reflects — including the October 2024 and October 2026 legal changes — our Equality, Diversity & Inclusion Training course covers everything in one programme.

Sources & references

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Mark McShane
Mark McShane
Health & Safety Training Specialist, Online CPD Academy

Mark writes about equality, diversity and inclusion, UK workplace law and accredited online training for Equality, Diversity & Inclusion Training, part of Online CPD Academy.