The gender pay gap reporting deadline for private sector employers with 250+ employees is TODAY, 4 April 2018, when the clock strikes midnight! Employers should have their reports at the ready and also be thinking about preparing for next year – as calculations will be based on pay data as at 5 April 2018. Below, we discuss the potential benefits of keeping interim pay gap improvements under review, between the “snapshot” and reporting date each year.
A recap of gender pay gap reporting
Broadly speaking, the gender pay gap calculations are designed to reveal the difference in mean and median hourly earnings and bonus payments between men and women over the previous 12- month period. Once the calculations have been completed, the figures will then be expressed as a percentage of male employees’ earnings/bonus. This means, for example, that where a pay gap is 50%, male employees’ are actually earning double that of their female colleagues. Calculations will also need to be done to show the proportion of men and women in each of the employer’s four pay quartiles, based on the employer’s own pay range and also the proportion of male and female employees who receive a bonus in the 12 month period.
Once published, an employee will be able to enter their employer’s name into the government’s website containing all reported pay data, to review their employer’s pay gap (if any).
The figures reported this year must be based on employees’ pay data as at 5 April 2017, which is known as the “snapshot date”. This means that the figures reported tomorrow will be retrospective and so do not necessarily reflect current pay levels or practices. The same will apply for 2019. Here, published reports will be based on pay data as at 5 April 2018 – i.e. data as at this Thursday!
Considerations for employers
The fact that published calculations reflect the “pay picture” for the previous year means that a published pay gap report’s calculations will not reflect any progress made in the year in which the report falls due/after the official snapshot date for that particular report (which falls on 5 April in the year prior to the report being published).
For this reason, we suggest that employers - particularly those that are taking active steps to reduce a pay gap- monitor pay gap process in the period following the report due date (4 April) until early into the following year so that an interim set of calculations can be done which will reflect this progress. For example, an organisation could chose its own snapshot date of 1 January and complete the gender pay gap calculations on the basis of data as at this date. It would not be possible for these figures to be included in the main body of the report, as they would not be based on the data required (i.e. data as at the official reporting snapshot date - the next one being 5 April 2018, in readiness for publishing the 2019 reports). Nonetheless, where these interim figures represent an improvement since the official snapshot date, it may add weight to any explanation given in an employer’s narrative that it is taking steps to reduce its gender pay gap. Our view is that this course of action will also help employers monitor progress and pre-empt any challenges for the following reporting year.
We can help
Boyes Turner employment group can help you calculate and prepare your gender pay gap report, prepare an accompanying narrative and offer further training on the subject. We can also offer specialist advice and assistance on this area.
For more information please contact the Employment team or Claire Taylor-Evans on [email protected] or 0118 9527284 for further information.
Consistent with our policy when giving comment and advice on a non-specific basis, we cannot assume legal responsibility for the accuracy of any particular statement. In the case of specific problems we recommend that professional advice be sought.