Gender pay gap reporting: who needs to report and how

Gender pay gap reporting is a legal requirement for private and voluntary sector employers with 250 or more employees. The reporting deadline for private sector employers is 4 April each year, using data from a snapshot date of 5 April of the previous year. Public sector employers have a snapshot date of 31 March and a deadline of 30 March. Failing to report is a breach of the regulations, which the Equality and Human Rights Commission can enforce.

The gender pay gap is not the same as unequal pay. The gender pay gap is the difference in average earnings between men and women across the entire workforce, regardless of role. Unequal pay is paying a man and a woman differently for doing the same or equivalent work — that is unlawful under the Equality Act. A large gender pay gap does not automatically mean unequal pay is occurring, though it may warrant investigation.

The six metrics you must report:

1. Mean gender pay gap — the difference between the mean hourly pay of male and female full-pay relevant employees, as a percentage of male mean hourly pay.

2. Median gender pay gap — the difference between the median hourly pay of male and female full-pay relevant employees, as a percentage of male median hourly pay.

3. Mean bonus gap — the difference between the mean bonus received by men and women as a percentage of male mean bonus.

4. Median bonus gap — same calculation for median bonus.

5. Proportion of men and women receiving a bonus — what percentage of male employees and what percentage of female employees received a bonus.

6. Pay quartiles — the proportion of men and women in each quartile of the pay distribution (lower, lower middle, upper middle, upper).

The calculation uses hourly pay from the snapshot date. For salaried employees, hourly rate is calculated by dividing monthly salary by hours worked in the month. For variable-pay workers, ordinary pay plus allowances are included; overtime, expenses, and benefits in kind are excluded.

You must publish the data on your own website and upload it to the government's gender pay gap reporting service. You are also required to publish a written statement confirming the data is accurate, signed by a director or equivalent.

While a narrative explanation is not legally required, it is strongly recommended. A gap figure without context invites negative headlines. An honest explanation of why the gap exists — a higher proportion of men in senior technical roles, a high proportion of women in part-time roles — combined with a credible action plan is a more credible public position.

See our HR policies guide for the equality policies that underpin gap reporting, and workplace pension duties for how pension contributions factor into pay gap analysis.

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