Gender pay gap reporting

  • Insight

30 March 2018

The deadline of 4 April 2018 for private sector employers to publish their gender pay gap information is fast approaching.

The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 requires all private sector employees with more than 250 employees to disclose information about their gender pay gap. An initial report must be published by 4 April 2018 with reports due on an annual basis thereafter.

What information must be disclosed?

The information that needs to be disclosed under the Regulations includes the following differences between male and female employees:

  • Average pay
  • Median pay
  • Bonus pay
  • Median bonus pay

What counts as pay?

For the purposes of reporting on the gender pay gap, pay will include:

  • Basic pay
  • Allowances (eg on-call allowances)
  • Pay for piecework
  • Pay for leave (only fully paid leave)
  • Shift premiums

Where should this information be disclosed?

The initial gender pay gap report and annual reports must be published on the employer’s own website. The report must be kept online and publically available for 3 years.

The information must also be uploaded to a government website.

What happens if you fail to disclose this information?

The Equality and Human Rights Commission has indicated that they will use their enforcement powers in the event that a company fails to disclose their gender pay gap information. Failure to disclose the information may constitute an unlawful act and could ultimately result in an order from the court to prepare an action plan for compliance. Any failure thereafter to comply with a court order could result in an unlimited fine.

For further information on this topic, please contact