Gender pay gap reporting in the United Kingdom
Reviewed by Mellow Editorial Team, HR & payroll content team
Employers with 250 or more employees must publish their gender pay gap data every year — reporting the difference in average pay between male and female employees across the whole organisation, not comparing pay for equal work.
Who must report
The duty applies to employers in Great Britain (England, Scotland and Wales) with a "snapshot date" headcount of 250 or more relevant employees. Private and voluntary sector employers use a snapshot date of 5 April; public sector bodies use 31 March.
Relevant employees include workers on your payroll at the snapshot date. Some categories — such as self-employed contractors who are not personally required to perform the work — may fall outside scope, but the boundary can be fine. If you are close to the 250 threshold, it is worth taking a careful headcount rather than assuming you are exempt.
Smaller employers are not required to report, but nothing prevents voluntary reporting, and some do so to signal transparency to candidates and staff.
What you must calculate and publish
Six specific metrics are required:
- Mean gender pay gap — the difference in average hourly pay
- Median gender pay gap — the midpoint difference in hourly pay
- Mean bonus gap — the difference in average bonus payments
- Median bonus gap — the midpoint difference in bonus payments
- Bonus proportions — the percentage of men and women who received a bonus
- Pay quartiles — the proportion of men and women in each quarter of the pay distribution, from lowest to highest
Hourly pay is calculated from a specific pay period that includes the snapshot date. Bonuses are drawn from the 12 months preceding the snapshot date.
All figures must be published on your own website and on the government's gender pay gap service. A senior person — a director, partner, or equivalent — must sign a written statement confirming the data is accurate.
The deadline for private and voluntary sector employers is 4 April each year (covering the preceding 5 April snapshot). Public sector employers must publish by 30 March.
Common reporting pitfalls
Conflating pay gap with equal pay. A gender pay gap does not mean women are paid less than men for the same job — that would be an equal pay issue, which is a separate legal matter under the Equality Act 2010. The gap reflects the distribution of men and women across roles and seniority levels. Both issues matter, but they require different responses.
Misclassifying workers. Contractors, agency workers and zero-hours workers each have different status rules. Including or excluding the wrong people skews your figures and, if the error is material, creates compliance risk.
Forgetting bonuses paid in the reference period. A bonus paid in the 12-month window counts even if it relates to performance from a prior period. Payroll records need to be clear on payment dates.
Publishing without a narrative. You are not legally required to provide a supporting statement, but publishing bare numbers without context leaves a gap for speculation. Most employers include a short written explanation of what drives their figures and what action they are taking.
Using the data to address underlying causes
The most common driver of a gap is occupational segregation — more women in lower-paid roles, fewer women in senior or technical positions. Publishing the pay quartiles makes this visible. If your lower two quartiles are heavily female and your upper two are heavily male, that is where the substantive work sits.
Practical measures employers use include:
- Structured pay bands with transparent criteria, reducing scope for negotiation-driven disparities
- Reviewing starting salaries, since gaps often originate at the point of hire
- Parental leave and flexible working policies that do not penalise time away — a relevant consideration given the Employment Rights Act 2025 strengthens day-one rights around flexible working requests
- Monitoring promotion rates by gender, not just pay levels
- Blind shortlisting and structured interviews to reduce bias in hiring decisions
None of these changes happen in one reporting cycle. Tracking year-on-year movement in your quartile distribution tends to be more informative than focusing solely on the headline mean or median.
Enforcement and reputational risk
The Equality and Human Rights Commission (EHRC) has enforcement powers, including the ability to investigate non-compliant employers and, ultimately, seek a court order. Fines are not the primary mechanism — it is investigation and reputational exposure that tend to focus minds.
Late or absent reporting is publicly visible on the government portal, which lists whether employers have submitted and when. Employment tribunal claims, candidate scrutiny and internal employee relations are the more immediate business risks for employers with a large or widening gap and no credible narrative around it.
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