Gender pay gap reporting is a legal obligation for UK employers with 250 or more employees on a specific snapshot date. Employers must calculate and publish six key metrics showing the difference in average pay between male and female employees. The requirement applies to private, public and voluntary sector employers and is enforced by the Equality and Human Rights Commission (EHRC).
Who Must Report
Private and Voluntary Sector
Employers with 250 or more employees on the snapshot date of 5 April each year must report. The reporting deadline is 4 April of the following year (12 months to prepare and publish).
Public Sector
Public sector employers use a snapshot date of 31 March and must report by 30 March of the following year.
Counting Employees
All relevant employees count towards the 250 threshold:
- Full-time and part-time employees
- Workers on fixed-term contracts
- Apprentices
- Some self-employed contractors engaged under a personal service contract
Agency workers are counted by the agency, not the hiring organisation.
What to Report
Employers must publish six figures based on pay data from the snapshot date:
| Metric | What It Measures |
|---|---|
| Mean gender pay gap | Difference in average hourly pay between men and women |
| Median gender pay gap | Difference in middle-point hourly pay between men and women |
| Mean bonus gap | Difference in average bonus pay received by men and women |
| Median bonus gap | Difference in middle-point bonus pay received by men and women |
| Bonus proportions | Percentage of men and percentage of women who received a bonus |
| Pay quartiles | Proportion of men and women in each of four equal pay bands |
How Pay Quartiles Work
All relevant employees are ranked by hourly pay from lowest to highest, then divided into four equal groups:
| Quartile | Employees Included |
|---|---|
| Lower | Bottom 25% of earners |
| Lower middle | 25th to 50th percentile |
| Upper middle | 50th to 75th percentile |
| Upper | Top 25% of earners |
For each quartile, the employer reports the percentage of men and the percentage of women.
Calculating Hourly Pay
Ordinary pay for the pay period that includes the snapshot date is used. This covers:
- Basic salary
- Allowances (e.g. shift premiums, London weighting)
- Pay for leave (annual leave, sick leave, maternity leave on full pay)
- Piece rates
It does not include:
- Overtime pay
- Redundancy pay
- Pay in lieu of leave
- Benefits in kind
- Expenses
Hourly Rate Formula
Hourly pay = Ordinary pay in the relevant pay period ÷ Working hours in the pay period
For salaried employees paid monthly, working hours are typically the contractual weekly hours multiplied by the relevant fraction of the month.
Calculating Bonus Pay
Bonus pay covers the 12-month period ending on the snapshot date and includes:
- Performance bonuses
- Profit share payments
- Commission
- Long-service awards paid in cash
- Share-based incentives (shares, share options)
Vouchers and non-cash bonuses that have a monetary value are included. The bonus gap calculations use actual amounts paid, not hourly rates.
Where to Publish
Employers must publish their gender pay gap data in two places:
- The government’s online gender pay gap service at gov.uk
- The employer’s own website, in a location accessible to employees and the public
The data must remain published for at least three years. While not a legal requirement, a supporting narrative explaining the figures and outlining actions being taken to address any gap is strongly recommended.
Enforcement
The EHRC monitors compliance and can take enforcement action against employers who fail to report:
- Investigation and compliance notices
- Court orders requiring publication
- Unlimited fines for non-compliance with a court order
- Reputational damage from being publicly named as non-compliant
The EHRC has entered into agreements with non-compliant employers and issued formal notices.
Gender Pay Gap vs Equal Pay
These are separate legal concepts:
| Concept | Meaning |
|---|---|
| Gender pay gap | The difference in average pay across an entire workforce — reflects workforce composition and seniority distribution |
| Equal pay | The legal right under the Equality Act 2010 for men and women to receive equal pay for equal work, like work or work of equal value |
An employer can have a lawful pay structure (no equal pay issues) while still having a significant gender pay gap because of an imbalance in representation at senior levels.
Connection to Payroll
Gender pay gap data is extracted from the PAYE payroll system. Accurate payroll records are essential for correct reporting. Employers should ensure:
- Pay elements are correctly classified as ordinary pay or bonus pay
- Working hours are accurately recorded for all employees
- Full-pay relevant employees are correctly identified (employees on reduced pay, such as those on maternity leave receiving statutory pay only, are excluded from hourly pay calculations but included in bonus calculations)
- The payroll system can extract data as at the snapshot date
Practical Steps for Employers
- Identify the snapshot date — 5 April for private sector, 31 March for public sector
- Extract payroll data for all relevant employees on the snapshot date
- Classify pay elements into ordinary pay and bonus pay
- Calculate working hours for each employee
- Compute the six metrics using the prescribed formulas
- Sense-check the results against previous years and known workforce composition
- Draft a supporting narrative explaining the data and planned actions
- Publish on the government portal and the employer’s website by the deadline
- Retain records for at least three years