Who needs to provide a gender pay gap report and when?
This reporting requirement was originally introduced in April 2017, and only applies to companies operating in England, Scotland or Wales with more than 250 employees on a specific date each year – also known as the ‘snapshot’ date.
If companies meet this criteria, they have a year from the snapshot date to publish their gender pay gap information. The snapshot date is 31 March for most public sector employers, and 5 April for those operating in the private or voluntary sectors. This means that the final deadline to submit this year would be
30 March for public sector employers, and 4 April for private and voluntary sector employers.
If your business is part of an organisation or group with more than one entity, a gender pay gap report needs to be published for each separate ‘legal entity’.
How to work out if you have 250 or more employees
Your 250-employee headcount would include the following:
- people with a contract of employment with you (including those that work part-time, job-share or who are on leave)
- self-employed people that have a contract to do work for you themselves
- any partners on a salary, or limited liability partnership (LLP) members who you treat as employees on your payroll
You would not include any agency workers in your headcount (such as the candidates that Blue Arrow places to fill temporary roles) as they would be part of the recruitment agency’s headcount.
What to include in your gender pay gap report
If your business has over 250 employees, you will be required to submit a report based on payroll data calculations taken on your snapshot date, that contains the following:
- A mean gender pay gap for hourly pay (the percentage difference in average pay of men and women across an organisation)
- A median gender pay gap for hourly pay (the difference between the midpoints in ranges of hourly earnings of men and women in a workforce)
- A mean bonus gender pay gap
- A median bonus gender pay gap
- Proportion of men and women receiving a bonus payment
- Proportion of men and women in each hourly quartile band (a pay quartile is calculated by listing the hourly rates for everyone across a business, then dividing them into four equal sized groups. The percentage of men and women in each group is then calculated).
Along with the above figures, you would be required to submit a written statement that’s signed by a senior employee confirming that all calculations are correct (although most public sector employers are exempt from doing this). In this statement, you can choose to provide a narrative to explain why a gender pay gap is present (if there is a gap), and what your business intends to do about closing any gaps.
The report needs to be made public once it’s ready to be published. This is usually made available somewhere accessible and prominent on your company website, and you’ll need to have it there for at least 3 years after publishing. Failure to report on your gender pay gap data is seen as unlawful, and if you don’t report on time with accurate data, the Equality and Human Rights Commission (EHRC) may take enforcement action in the form of court orders and fines.
Working to achieve gender equality
As leaders in diversity, we welcome the opportunity to report on our gender pay gap figures each year, and believe that it’s a great way for our clients and other businesses to monitor trends within their organisations and demonstrate any progress to achieving gender equality.
Initiatives that we support to help us achieve our equality, diversity and inclusion goals include:
- participating actively in a group network which encourages positive conversations that drive clear action
- addressing unconscious bias via online staff training
- facilitating conversations around flexible working
For more information on gender pay gap requirements visit the UK government website. Alternatively view our other industry insights articles for other insights and advice.
