All organisations with over 250 employees need to report annually any average pay differences between male and female employees by April 2018.
Employers are required to publish the following information:
- Mean pay gap between male and female employees
- Median pay gap between male and female employees
- Mean bonus pay gap between male and female employees
- Details of the number of men and women working across salary quartiles
The first gender pay reports will have to be published by 4th April 2018 and will be based on pay rates as at 5th April 2017. The bonus pay gap will be based on bonuses paid between 6th April 2016 and 5th April 2017.
The reports have to be published annually on an organisation’s UK website in a format that is accessible by employees and members of the public. The reports must remain on there for 3 years to enable progress to be monitored as subsequent reports are added over the years. Employers must also submit evidence of compliance to the Government which will involve uploading the report to a government website where it can be accessed by the public.
There is no obligation on an employer to publish any narrative to accompany the reports but we would advice employers to do so as it gives you an opportunity to explain why there may be a particular gap in your business. For example providing pay information based on grade or job type or full-time and part-time working is likely to be more accurate and show a smaller pay gap.
What happens if you don’t publish a gender pay report?
Whilst there are no specific sanctions for private sector employers who fail to comply, there are significant reputational risks for those who do not. In this regard the Government has already said that it may name and shame any offenders and any organisation included on such a list is likely to see not only damage to its reputation but also its ability to recruit and retain staff and secure future work particularly in the public sector.
How can we help?
We can help you prepare for the introduction of gender pay gap reporting by conducting a gender pay review now to identify any gender pay gaps that exist and work with you to identify any steps you can take to reduce any gap. Any advice you receive from us will be subject to legal privilege which means any discussions we have will not have to be disclosed in the event of any future litigation.
We can also help produce the formal report providing suitable commentary to explain any gender pay gaps that may exist.
Get in touch now
If you would like more information on your gender pay reporting obligations please contact a member of our Employment Team.