Gender pay gap reporting Year 2 deadline fast approaches!


The government introduced mandatory gender pay gap reporting on 31st March 2017 in a bid to highlight and reduce the longstanding gender pay gap. The first year of gender pay gap reports were due on or before 4th April 2018 and the deadline for the second set of reports on 4th April 2019 has almost arrived.     

The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (GPG Regs) apply to any company, LLP, partnership, limited partnership, unincorporated bodies or other type of employing entity with 250 or more employees who are employed on the snapshot date of each relevant year.

The GPG Regs provide a wider definition of employee, defining it as anyone who works: Under a contract of service, a contract of apprenticeship or a contract personally to do work. This means that employers are required to include employees, casual workers and some contractors.

The GPG Regs require three reports: A gender pay gap report, a gender bonus gap report, and gender salary quartiles. These reports must be published on the company website and the government portal. If an employer does not have a website, they are required to create a website for these purposes. The reports must remain on the website for at least three years after publication.

To calculate pay, employers are required to use the employees’ earnings (basic pay, allowances, pay for piecework, pay for leave and shift premium pay) earned during the relevant period that fall on the snapshot date of 5th April each year. The relevant period is the month (if paid monthly), the fortnight (if paid fortnightly) or the week (if paid weekly) that includes 5th April.

Employee bonuses, as well as having their own report, require inclusion in the headline report if paid within the relevant period. If an employee receives an annual bonus, paid in a single sum within the relevant period, the employer must include the payment in the calculation but is entitled to pro-rata it.

Employers can, voluntarily, provide a narrative to accompany their reports. This is an opportunity to explain any anomalies or distortions and gives the employer the opportunity to detail how they plan to reduce their gender pay gap in future.

Before 4th April 2019, employers who have not done so yet will be required to complete and publish their reports.

We regularly assist employers on their Gender Pay Gap reporting obligations. If you require assistance with your ongoing reporting obligations or if you are required to report for the first time and need our help, please contact a member of our Employment team on 0161 941 4000 or by email