Mandatory gender pay gap reporting – a reminder for employers


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The Equality Act 2010 (Gender Pay Information) Regulations 2017 came into force on 6 April 2017 and private or voluntary sector employers with at least 250 employees must report their gender pay gap data by 4 April 2018.

As a quick reminder employers are required to report:

  • The overall gender pay figures calculated using both the mean and the median based on the snapshot date of 5 April. The median is thought to be the best representation of the typical difference between the genders as it is not distorted by the small number of very high earners;
  • The number of men and women in each of 4 salary quartiles, based on the employer's overall pay range. This will show how the gender pay gap differs across the organisation, at different levels of seniority; and
  • Separate information on the mean and median gender pay gap relating to bonuses.

The report must be signed by the CEO and will appear on the government's dedicated website and the employer's own website for at least three years. The employer can also include a narrative explaining their figures and any plans to address the gender pay gap.

There are no sanctions against employers who fail to comply contained in the Regulations themselves, however the Equality and Human Rights Commission (EHRC) has recently published its draft enforcement strategy (and has also opened a consultation on the strategy which closes on 2 February) for pursuing employers who fail to comply with their gender pay reporting duties. Initially the EHRC will seek to engage cooperatively and informally with employers in breach. They will then use their wider enforcement powers which may culminate in the issuing of unlimited fines and summary convictions for those employers who have failed to comply.

Action point

Time is running out! If you haven't done so already, start compiling your gender pay gap figures in preparation for the reporting deadline of 4 April.

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