Gender pay reporting advice note

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Gender pay reporting advice note



The final Gender Pay Gap Information Regulations were published in December 2016 and should come into force on 5 April 2017. The aim is to capture the difference in hourly rates of pay between male and female employees.


Key Provision

Annual reports must be produced based on ‘snapshot’ date of pay data as at 5 April 2017 (latest report date 4 April 2018 and annually thereafter).


Who does it apply to?

Voluntary and private sector organisations with 250 or more employees as at 5 April 2017 (and annually thereafter). Group companies do not have to aggregate employees across subsidiaries. Public sector employers have separate reporting obligations.


What information should be published in the annual report?

  • Overall gender pay gap figures calculated in accordance with a set formula related to average hourly pay of full pay relevant employees (excluding those who had been paid at a reduced or nil rate due to leave in that year)
  • Numbers of men and women in each of the 4 pay bands
  • Information on gender bonus gap
  • Proportion of men and women receiving a bonus in the same 12 month period
  • Voluntary narrative of any other pay gaps and action plans


  • Those paid in April to be pro-rated and included in hourly rate calculations
  • Separate bonus reporting requirement relating to bonuses/payments linked to productivity, performance or commission earned.
  • Bonuses awarded as securities, securities options and interests in securities included as bonus pay
  • Bonus payments require employers to look back over preceding 12 months

Where and when should the annual report be made?

  • Annually
  • On the employer website for 3 years

  • Upload to government website

What pay is excluded?

  • Overtime
  • Expenses
  • Value of salary sacrifice
  • Benefits in kind
  • Redundancy pay
  • Arrears of pay
  • Tax credits

The Government and Acas have produced draft guidance here on managing gender pay reporting.


tFor more information on employment law or related enquiries, please contact Abigail Maino, Solicitor, Employment.

View Abigail's profile email Abigail now 

Published: 31 Jan 2017

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