We investigate the renormalization group (RG) structure of the gradient flow. Instead of using the original bare action to generate the flow, we propose to use the effective action at each flow time. We write down the basic equation for scalar field theory that determines the evolution of the action, and argue that the equation can be regarded as a RG equation if one makes a field-variable transformation at every step such that the kinetic term is kept to take the canonical form. We consider a local potential approximation (LPA) to our equation, and show that the result has a natural interpretation with Feynman diagrams. We make an ε expansion of the LPA and show that it reproduces the eigenvalues of the linearized RG transformation around both the Gaussian and the Wilson-Fisher fixed points to the order of ε.