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Gender Pay Gap Reporting

By Julia Penny

The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (SI 2017/172) set out the requirements for relevant employers to publish information about their gender pay gap. Certain of this information has to be published on a government website set up for that purpose and a more detailed report must be made available on the company’s own website.

The Regulations require employers with 250 or more employees on 5th April in any given year (a relevant employer), to publish their gender pay gap information within the following 12 months. Employment is as defined in the Equality Act, so includes those with a contract of employment, an apprenticeship or a contract to personally do work for the employer (eg freelancers or contractors). Note that an employee does not include a partner in a firm, so employers that operate as partnerships might have rather different data to those that operate in corporate structures. The information must be published within the following 12 months, using the 5th April as the snapshot date for reporting.

The figures required to be reported are very formulaic, in order to ensure consistency across the information reported and, as mentioned above, are done at a single point in time, the snapshot date. For the purpose of calculating hourly rates etc, the payroll period which includes the 5th April is used, so for monthly payrolls April figures are used for the calculations, though for bonuses the figures are in relation to the 12 month period ending in the snapshot date.

In outline the information required to be reported is the difference between the male and female employees':

  • mean hourly rate of pay;
  • median hourly rate of pay;
  • mean bonus payments;
  • median bonus payments.

Also required are:

  • the proportions of relevant male and female employees who were paid bonuses; and
  • the proportion of male and female full-pay relevant employees in quartile bands

(For contract staff the information above need not be reported where it is not available and is not reasonably practicable for the employer to obtain).

The information on the government website looks like this, with a search facility to find a particular organisation:


As you can see, quite a lot of detailed information is required and much of it might take some effort to extract from the systems. Therefore, if you or your clients have more than 250 employees and haven’t already got the preparation of the information in hand, then best to look at it soon, as the 5th April deadline for the first report is fast approaching.

Remember also, that the impact of reporting such figures might well create either a PR issue or an issue with staff, who perceive a level of unfairness. Of course it is already illegal to pay male and female employees different amounts for the same grade of work, but the gender pay gap reporting, in highlighting the differences, could occasionally lead to identification of an equal pay issue or a perception of one.

Generally though, the gender pay gap is about recognising that there is an imbalance of males and females in different roles in a business, usually meaning that on average, females are paid less, as fewer of them are in the higher salary brackets. By highlighting the discrepancies the government is calling on employers to look at how they can shift the pay gap, which also links into a number of the proposals in the corporate governance code consultation. There are other initiatives as well, such as the Women in Finance Charter, which is encouraging financial services organisations, such as accountants, banks etc to commit to gender balance in the sector.

So as well as calculating the figures themselves, you or your clients will need to think carefully about how you word the narrative around the figures, whether you sign up to a relevant charter and what other messages you want to provide in respect of your gender pay gap (if you have one). 

February 2018 


This article is published with the understanding that SWAT UK Limited is not engaged in rendering legal or professional services. The material contained in this article neither purports, nor is intended to be, advice on any particular matter. This article is an aid and cannot be expected to replace professional judgment. SWAT UK accepts no responsibility or liability to any person in respect of anything done or omitted to be done by any such person in reliance, whether sole or partial, upon the whole or any part of the contents of this article.