Gender pay gap reporting established


BOND ADAMS EMPLOYMENT UPDATE by Dispute Resolution Partner, Rafique Patel

Employers with 250 or more employees will be required to publish details of their gender pay gap and gender bonus gap on a yearly basis.


It is expected that the first reports will need to be published by April 2018.

However, the pay information will need to be based on payments made over the employer’s pay period every April, beginning in April 2017.


The bonus information will need to cover the preceding 12-month period, beginning with the 12 months leading up to April 2017.


Although gender pay gap reporting legislation does not come into force until early 2017, employers may have to collect gender pay gap data from as early as April 2016. HR professionals can use this timeline to get ready for their reporting obligations.


Now: Check that your organisation collects the data needed to conduct gender pay gap reporting. Information must be collected on employees as defined under s.83 of the Equality Act 2010, which includes apprentices and workers who have a contract personally to do work.


Consider if additional data would be useful for internal analysis of gender pay gaps. For example, it may be useful to gather figures on the gender profile of your organisation, bonus trends across your organisation, or your organisation’s historical gender data in order to understand gender pay gap results.


Consider conducting a test gender pay gap analysis based on data from prior years. This will confirm that your organisation is ready to meet regulatory requirements. It will also allow your organisation to anticipate gender pay gap results and begin to address any potential concerns.


5 April 2016:  Begin to collect data for the first reporting period. As bonus pay data includes payments from the year preceding 5 April 2017, you may need to collect figures on bonus payments from as early as 5 April 2016. Pay data covers payments for the April 2017 pay period.



Early 2017: The Equality Act 2010 (Gender Pay Gap Information) Regulations for private and voluntary-sector employers are expected to come into force around this time. They will require all private and voluntary-sector employers with 250 or more employees to publish prescribed information about their gender pay gap results.


6 April 2017: Begin to carry out calculations to determine your gender pay gap results.


4 April 2018: Publish the results of the gender pay gap analysis on your organisation’s website by 4 April 2018. The results must be posted in a publicly accessible manner. A signed statement that the information is accurate must accompany the results and the results must remain on the website for at least three years.


Upload the gender pay gap analysis results onto the Government’s reporting website.

Although commentary on the gender pay gap results is not required, organisations should consider adding a narrative to help employees and the public understand their results, particularly in cases where gender pay gaps seem significant. Alternatively, commentary can help highlight an organisation’s strong performance relative to its competitors.

Consider creating an action plan to address gender pay gaps. Although this is not required, it is encouraged by the Government in pursuit of gender equality in the workplace.



For advice on all aspects of employment law including representation in the employment tribunal, representation in the Employment Appeal Tribunal and the courts, contact our partner Rafique Patel on

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