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Gender Pay Reporting FAQs: who reports and how?

16 January 2018

During our discussions with clients a lot of the same questions are raised. Here we summarise some of these for you. For further information you should download our Gender Pay Reporting guide.

  1. Who has to submit a gender pay report?

Any organisation who employed 250 or more employees on the Snapshot Date of 5 April 2017 is a Relevant Employer and must submit a GPR by 4 April 2018. For each year thereafter, any organisation which has 250 or more employees on 5 April each year will have to report.

  1. Where do I submit my gender pay report?

The gender pay report must to be uploaded to the Government sponsored gender pay reporting website at

The above link gives the ability to link to the organisation’s own website, where a copy of the report must be kept for a minimum of three years and where an optional narrative can be provided.

  1. Can we view the gender pay information for other organisations in our sector?

The reports of all organisations covered by the regulations are available to view at Organisations may wish to include analysis and commentary around their competitors within a sector in their own narrative.

  1. Do we have to share our gender pay reporting with our employees?

Given increased transparency and media scrutiny around gender pay, organisations may wish to consider carefully how it will communicate its own gender pay figures with employees. It will be vital to ensure that the organisation has effective internal communication and a sound narrative.

  1. Who is responsible in our organisation for gender pay reporting?

The answer is two-fold. A senior employee will need to ‘sign off’ the report and confirm it is accurate. This will usually be a named director or equivalent within an organisation. However, in preparing the report, this is likely to include staff from multiple areas of the organisation and will likely include HR, payroll and reward staff.

  1. Our payroll is run at the end of April. How should we deal with leavers and joiners between 5 April and the end of the month?

The date on which you will assess the number of employees for the purposes of the 250 employee threshold and which employees to include in your calculations will be 5 April each year (the Snapshot Date). If someone joins on 6 April they should not be included in this year's report. If an employee leaves on 2 April, they should not be included since they will no longer be an employee on the Snapshot Date.

  1. Should we exclude consultants where we don't know how many hours a week our consultants work?

There is scope to exclude self-employed consultants where an employer does not have and it is not ‘reasonably practicable’ to obtain the data needed for its Gender Pay Reporting. The ACAS guidance does suggest that before excluding such a consultant, the employer should try to obtain the information needed by asking the consultant.

  1. I have two employees on maternity leave. One will still be on full pay on 5 april and the other employee is only receiving statutory maternity pay. Do i include them?

The employee who is on leave and receiving full maternity pay would be included in the headcount of 250 employees and all of the calculations, because she will still be receiving full pay. If the employee on statutory maternity pay is receiving less than her usual full pay, she should be included headcount of 250 employees and in the Bonus Pay calculations but not included in the hourly rate of pay calculations.

  1. I have an employee who does not self-identify as either male or female –how do i treat them for gender pay?

The regulations do not address this sensitive issue. However, the guidance suggests that employers should use the gender identification the employee has provided for HR/payroll purposes. For employees who do not self-identify as either male or female, the guidance notes state that employers can omit these employees from their calculations.

  1. We have a number of internationally mobile employees. How do we know whether we should include them in the gender pay calculations?

The application of GPR to an organisation’s mobile employees is not straightforward. Whether to include overseas employees will largely depend on where their employment connection is and determining that can be complex. The guidance and commentary suggests that if an employee would be able to bring a claim to a GB employment tribunal under the Equality Act 2010, they would be within the scope of the regulations (and therefore included in the 250 employee headcount and subsequent calculations). The guidance goes on to state that whether this is the case will depend on whether the employment relationship suggests a stronger connection to GB employment law than to the law of any other country. If it is not clear to you, take advice.

What is pay for GPR purposes?

  1. How do i calculate working hours where employees work varying hours over different weeks?

The regulations normally require you to use a 12 week reference period to determine the weekly hours and average over that period.

If you have employees who work rotas or shifts –for example, with say two weeks on and two weeks off –then the regulations operate to exclude the weeks in which no hours are worked. Within a 12 week reference period this could otherwise result in an unrepresentative and low hourly rate, so employers should adopt a fair and reasonable approach to obtain an average in these circumstances and may wish to provide some narrative on such issues.

  1. Our long term bonus plan pays out a bonus on 30 april 2017 relating to a three year performance period. Do we pro-rate it?

For calculating hourly pay rates Bonus Pay would only be included if it is received during the Relevant Pay Period. If 30 April 2017 falls within earnings period which straddles the Snapshot Date of 5 April 2017 then it is included. Note that because it is paid after 5 April 2017 it would not fall into that year’s Bonus Pay figures.

The bonus has been earned over a three year performance period and so for the hourly rate calculations it is pro-rated. Assuming the employee is paid monthly the addition to their other relevant monthly pay would be:

[Bonus X 30.44 days / (365.25 days  X 3)].

  1. We paid a bonus to a part-time member of staff? Do we scale it to produce a full time equivalent figure?

No. Use the figure actually paid to the part-time employee. If this distorts your bonus gap because you have a high proportion of part-time employees, consider providing an explanation in your narrative.

  1. Are pension contributions counted as pay?

This will depend on the administration of the pension and there is a distinction between employer and employee pension contributions. Employer pension contributions are not considered ‘pay’ since these are contributions paid by the employer rather than monies deducted from the employee's pay. Employer contributions, therefore, will not affect the gender pay gap hourly or bonus figures. Where employee contributions are made to a pension via salary sacrifice, include their pay after the salary sacrifice reduction. The salary sacrifice is not considered pay because the employee has given up their contractual entitlement to it and it is no longer considered to form part of their salary.

  1. Our organisation provides a season ticket loan to employees. Is this included in pay?

No. Loans to employees, such as an annual season ticket loan, are not counted as ‘pay’ for the purposes of gender pay reporting.

  1. We provide company cars to selected employees. Do we include these in the pay figures?

Benefits in kind are excluded. The benefit of providing a company car would not be counted as ordinary pay. However, if an employee elected to receive a cash payment instead, then this would be included.

  1. Can we ignore insignificant pay elements?

No.  You cannot ignore a pay element just because it small.