Gender pay gap reporting in Australia
Reviewed by Mellow Editorial Team, HR & payroll content team
Employers with 100 or more employees must report their gender pay gap data to the Workplace Gender Equality Agency (WGEA) each year, and from 2024 WGEA publishes employer-level results publicly. Smaller employers are not captured by the mandatory scheme, but the reporting framework is worth understanding regardless of your headcount.
Who has to report and when
The Workplace Gender Equality Act 2012 covers private-sector employers with 100 or more employees. These employers must submit a report to WGEA each year covering the period 1 April to 31 March, with the submission due by 31 May.
The report covers six gender equality indicators:
- gender composition of the workforce
- gender composition of governing bodies
- equal remuneration between women and men
- availability and utility of flexible working arrangements
- consultation with employees on gender equality matters
- policies or strategies relating to each of the above
From the 2023–24 reporting cycle onward, WGEA began publishing each employer's gender pay gap as a specific percentage — not just a range — on its public website. That shift from aggregate data to named figures changed the stakes considerably. Customers, job candidates and investors can now look up your organisation directly.
How the gender pay gap is calculated
WGEA measures the gap as the difference between the median total remuneration of men and the median total remuneration of women, expressed as a percentage of men's median. Total remuneration includes base salary, superannuation, bonuses, allowances and other earnings.
It is worth being clear on what the figure does and does not show. A gender pay gap is not the same as unequal pay for equal work. The gap reflects differences in the roles women and men hold, the industries they work in, the hours they work and how seniority is distributed across the organisation. Understanding the drivers of your own gap is the analytical step that comes before deciding what to do about it.
Two figures to track internally:
Like-for-like pay gap — comparing remuneration for people doing the same or substantially similar roles. A gap here is the clearest signal of a direct pay equity problem.
Workforce composition gap — reflecting occupational segregation and representation at senior levels. This usually takes longer to shift and requires action on hiring, promotion and retention rather than pay adjustments alone.
Reading your own data
Before you can act, you need a clean picture of what you actually pay. That means pulling data by gender across business unit, level, employment type and tenure — not just a single organisation-wide average.
Key questions to work through:
- Is the gap concentrated in a particular team or level?
- Are women underrepresented in higher-paid roles, or are people in equivalent roles paid differently?
- Does the gap widen when you include variable pay and bonuses?
- How does parental leave affect tenure-based pay progression for women?
Superannuation is increasingly part of this conversation. Because the Superannuation Guarantee (12% of ordinary time earnings from 2026) is calculated on ordinary time earnings, employees who take unpaid leave accumulate less super over time — a gap that compounds across a career. Some employers now pay super on unpaid parental leave as a deliberate equity measure.
Practical steps for employers
Conduct a pay equity audit. This does not need to be a large consulting project. Start with a spreadsheet: list every employee, their gender, role, level, base salary, total remuneration and tenure. Compare medians and means within like-for-like groups. Flag outliers.
Document your pay structures. Discretionary pay decisions create the most risk. If managers set salaries without reference to a salary band or a consistent framework, gaps accumulate over time without anyone intending them to. Banding roles and publishing ranges internally reduces variation.
Review your variable pay rules. Bonuses, commissions and allowances are often where gaps are largest and least visible. Check whether eligibility rules or payout timing disadvantages employees on parental leave or part-time arrangements.
Set a baseline and track change. Reporting to WGEA once a year is a compliance event. Internal tracking should be more frequent — at minimum, after each remuneration review cycle. Understanding whether your gap is narrowing, stable or widening is a basic management discipline.
Communicate honestly. If you have a gap and you know why, say so internally. Employees generally respond better to an honest explanation and a stated plan than to silence or spin. WGEA's public disclosure means the figure is available anyway.
Non-compliance and reputational risk
Employers who do not submit their WGEA report on time can be named publicly as non-compliant, and they become ineligible to tender for Commonwealth contracts. The financial and reputational costs of non-compliance are straightforward to avoid — the reporting process itself is not onerous once your payroll and HR data are in reasonable order.
For businesses considering how payroll data flows into workforce reporting, how Mellow runs payroll across six countries gives a sense of how centralised data structures make this kind of analysis easier at scale.
The substantive challenge for most employers is not the report itself — it is deciding what to do with what the data shows.
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