Gender pay gap reporting deadline: Q&A on requirements and emerging market practice

Gender pay gap reporting deadline: Q&A on requirements and emerging market practice
Corporate analysis: With the deadline of 5 April 2018 approaching for companies to submit gender pay gap information, here’s a recap of what’s required, and a summary of the market practice we have observed so far.

What’s required?

On 6 April 2017, the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, SI 2017/172 (the Regulations) came into force. The Regulations require employers with 250 or more employees to publish information on the gender pay gap in their organisation within one year, and on an ongoing basis for each subsequent year.

Under the Regulations, relevant employers are required to publish information on:

  • the differences between mean and median hourly rates of pay and bonus pay of male and female full-pay relevant employees
  • the proportions of male and female relevant employees who were paid bonus pay
  • the differences between mean and median bonus rates of pay of male and female full-pay relevant employees, and
  • the proportions of male and female relevant employees in lower, lower middle, upper middle and upper quartile pay bands

This information must be published on the employer’s website for a period of at least three years, beginning with the date of publication, in a manner that is accessible to all its employees and to the wider public.

The details must be accompanied by a signed, written statement confirming its accuracy.

When is the deadline?

The first one-year deadline is fast-approaching for companies and charities, who must comply with the Regulations by 5 April 2018. Public sector bodies have an earlier deadline of 31 March 2018.

What are the consequences for not complying?

Failure to comply with an obligation imposed by the Regulations constitutes an ‘unlawful act’ within the meaning of 

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