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Gender Pay Gap reporting requirements

The Government have recently published draft Regulations governing the compulsory reporting of gender pay gaps by employers with more than 250 employees.  It is intended that the regulations will come into force on 1 October 2016 and will require affected employers to take a preliminary data snapshot in April 2017, followed by publication of a full report by no later than April 2018.

What will I need to publish?

The draft Regulations outline that the following data will need to be published:

  • The difference between pay for male and female employees on a mean (average) basis.
  • The difference between pay for male and female employees on a median basis.
  • The difference in mean bonus pay, during the 12 months preceding the relevant date.
  • The proportion of male and female employees who received bonus pay during the 12 months preceding the relevant date.
  • The number of male and female employees employed on the relevant date in specific pay bands, calculated by the employer based on its overall pay range.

When is the relevant date?

Employers will be required to take the data snapshot on the 30 April each year and must then publish their gender pay information at any time within 12 months of that date.

Where will it be published?

The information must be available for three years and published on the employer’s website and uploaded on a government-sponsored website.

Penalties for non-compliance

At this stage, there are no civil or criminal penalties for failure to comply, instead the Government is relying on an expectation that employers will comply, backed up by the potential for the identities of non-compliant employers to be publicised. The position will however be kept under review during the first few years of implementation.

Despite being in draft form, the Regulations are more rigorous that anticipated and will likely take employers a period of time to implement once finalised and published. Employers may however be reassured to learn that ahead of the commencement of the reporting obligations, the Government will be preparing a package of guidance and support for the employers who fall within this legislation.

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You can access the report here.

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