Gender Pay Gap Reporting - Practical guidance for employers

The gender pay gap reporting regulations “The Regulations” came into effect in 2017 in a bid to tackle the difference in average pay of men and women in all roles across the labour market. The Regulations require companies with 250+ employees in the UK to calculate and publish the pay gap between male and female employees on an annual basis by 23:59 on 4 April.

Who needs to report and when?

The Regulations require businesses to measure their mean, median pay and bonus gaps and the proportion of males and females in each pay quartile based on data from 5 April “the snapshot date”. The report must be published on your company website, and on a publicly available Government portal.

Gender pay gap statisitics and key trends

The Office for National Statistics recently released a summary of the results from last year’s round of pay gap reporting which saw a decrease in the gap from 7.1% to 6.9%, a smaller reduction than in previous years. Over the last decade the gender pay gap has narrowed by 25% overall but it still remains. It exists due to a combination of factors, women being overrepresented in lower paying sectors, societal norms and the “motherhood penalty” borne out by the fact that the gap becomes more pronounced after the age of 40, reflecting the effect that interruptions for maternity leaves and childcare have on careers.

The Regulations were introduced to force companies to measure their pay gaps in the hope that this would also lead them to ultimately manage and address the underlying causes.

What's changing & action plan going forward

However, currently, companies are required only to publish their pay gaps. Other than potential reputational damage if there is a significant divide, there are no penalties for having a pay gap. Whilst many companies do already create plans to address the gap, from 2027 the Employment Rights Act 2025 will require you to publish gender equality action plans detailing how your organisation is tackling the gap. We will need to wait for consultation followed by implementing legislation from government to understand what will need to be reported and the consequences for employers who do not. We are also expecting the Equality (Race and Disability) Bill to be published this year, which is likely to require any organisation caught by gender pay gap reporting requirements to also report pay gaps for disabled and ethnic minority employees.

Top tips for compiling you gender pay gap report

Having worked with many clients to produce their gender pay gap reports, our top tips for compiling yours are:

1. Don’t miss the deadline, last year 10 organisations missed the filing date and were named and shamed by the EHRC, who publish a list of non-compliant companies on their website.
2. Smaller employers should check whether they have tipped into the employee threshold of 250 employees during the course of the year, based on the relevant snapshot date. 
3. Review your pay elements now. This is particularly important if you have changed these over the last year. These are essential in working out the difference in hourly rates between men and women:
4. Check you have captured the right employees. The definition of employee for reporting purposes is wider than for employment law purposes. If you engage any self-employed contractors check whether they are included in the definition.
5. Check your data integrity. If you are importing or exporting large amounts of data remember that this gives rise to significant opportunity for errors.
6. Don’t rely on automatically generated payroll systems figures “hourly rates”. These are not always compliant with the Regulations.
7. Calculations vary according to different factors and some should only include full pay employees. Remember full pay can be affected by periods of family leaves. 
8. Identify the correct employee pool: make sure you are comparing the right groups of employees. For example, bonuses should be compared only between employees who receive bonuses.
9. Don’t leave it too late to begin preparation. The reporting process can be labour intensive and time consuming.
10. Make sure your report is accurate. The Regulations require you to undertake complex calculations and are specific about what elements should be contained within each calculation. There is significant societal and media interest in companies diversity statistics and gender pay gap reporting data, so it is very important to ensure the report is prepared correctly.

How we support UK employers with gender pay gap reporting

We provide a full gender pay gap support package which includes:

• Liasing directly with payroll providers to request the relevant information;
• Resolving queries and clarification relating to any anomalies or incomplete data to ensure the resulting report is accurate and fully compliant;
• Preparation of the gender pay gap report in accordance with the Regulations with an accompanying explanatory document; and
• An optional narrative and (if applicable) comparison with previous year’s data.

Contact us today to discuss how we can help your organisation meet current obligations. We can also support more broadly with DE&I strategy, coaching, training and mentoring, if required.​​​