Reporting Duties for Employers in the UK: The Gender Pay Gap

The Gender pay gap refers to the difference in average earnings between men and women. This will often be expressed as a percentage figure and can be analysed across the workplace, an industry, region or other factor. According to the Office for National Statistics (ONS), as of October 2024, the gender pay gap for all recorded UK employees was 13.1%, showing that for every £1 a man earned, a woman earned 87p.  It is important to address this disparity to promote fairness and equality in the workplace.

Gender Pay Gap Reporting

Gender pay gap reporting is mandatory for employers with 250 or more employees. These organisations are required to publish annual reports detailing pay disparities between men and women.

What Happens if You Don’t Publish Your Gender Pay Gap Report?

If you report inaccurately, or do not report your gender pay gap, the Equality and Human Rights Commission (EHRC) may take legal action against you which could lead to court and fines.

Aside from this, your business may face reputational damage as a ‘late badge’ will be marked against its name and made visible to the public through the gender pay gap service.

Current Reporting Deadlines

Employers must report and publish their gender pay gap information within a year of their snapshot date. Private Limited companies have a snapshot date of 5 April 2024 and for most public authority employers, the snapshot date is 31 March.

Therefore, the current reporting deadlines you need to be aware of are:

• 30 March 2025: For most public authority employers.
• 4 April 2025: For private, voluntary, and all other public authority employers.

Proposed Changes to Pay Gap Transparency

The government has proposed changes to enhance pay gap transparency. These proposals include requiring employers to develop and publish equality action plans, detailing steps to address their gender pay gaps and support employees through various stages of their careers. Additionally, it also intends to introduce mandatory ethnicity and disability pay reporting for employers with over 250 employees.

Preparing for Reporting Requirements

Employers can take several proactive steps to prepare for gender pay gap reporting:

1. Collect Accurate Data: Gather accurate data on employee pay, bonuses, and working hours, ensuring that information is separated by gender.
2. Record Various Measurements of Data: Calculate the required metrics, including the mean and median gender pay gaps, bonus pay gaps, and the distribution of male and female employees across pay quartiles.
3. Explain the Figures and Break Down the Action Plan: While not mandatory, providing a narrative that explains the figures and outlines an action plan to address any identified gaps can demonstrate a commitment to equality and help contextualise the data.
4. Review Policies: Assess current recruitment, promotion and pay policies to identify potential areas of bias or barriers to equality.
5. Train Your Employees: Implement training programs to raise awareness about unconscious bias and promote inclusive workplace practices.

By taking these steps, employers not only comply with legal requirements but also contribute to creating a more equitable workplace.

How We Can Help

If you have any questions on gender pay gap reporting or would like any general employment law advice, please contact Nicola O’Dwyer – Nicola.odwyer@ibblaw.co.uk.