Gender Pay Reporting

23 February 2022

In the two previous reporting years the Gender Pay Gap reporting obligation has either been suspended or enforcement has been delayed, as a result of the COVID-19 pandemic. We are now back to the usual reporting cycle of 4 April 2022 for the private sector. That is not to say that the impact of COVID-19 on the figures has passed and that organisations will not still face challenges in producing meaningful and comparable figures, however. We have highlighted separately how COVID-19 has likely impacted organisations.

Read our full article on the impact of COVID-19 on gender pay reporting.

The Gender Pay Gap regulations have now been with us for a total of nearly five years and when published, the legislation committed the Government to a review after five years and thereafter every five years. As such, in 2022 we can expect to hear whether the Government consider the regulations to be working and whether they will accede to some of the arguments made over the past five years as to whether the regulations go quite far enough. 

Possible areas of change might be:

  • Expanding the scope of Gender Pay Gap reporting to a wider group of employers and reducing the threshold to employing entities with a lower number of employees. This could potentially expand the reporting obligations to a large number of employers who are not currently impacted by the 250+ employee threshold.
  • Requiring more actionable commitment to change from employers by making an accompanying narrative to the published figures mandatory – or going further still by requiring a measurable action plan to be published alongside the figures.
  • Making the analysis of the figures more forensic, such as requiring full time and part time figures to be analysed, or potentially reporting not by quartiles, as is currently the case, but by reference to smaller segments of employees such as deciles.

Whether organisations are currently within scope or expect to be imminently, BDO's team are on hand to assist with any queries and preparations you may wish to make now.

Gender Pay Reporting Timeline: What and When? 

Gender Pay regulations now require private sector employers with more than 250 employees, at company or entity level, to publicly report a range of gender pay information and six GPR ratios by 4 April every year. Slightly different dates apply to public sector employers who must report by 30 March each year.

The regulations were brought in to reduce and eventually eliminate the gender pay gap. The principal of equal pay has been long established in law and it is already illegal to pay women less on average than their male counterparts. However, differences in gender representation at different levels of an organisation can create a gender pay gap.

Understanding which data needs to be included in a report; how, where and when to report the information; and preparing an effective ‘narrative’ are just some of the challenges of Gender Pay Gap Reporting.

We have produced a comprehensive, practical guide to help you understand and overcome the challenges of Gender Pay Reporting. You will also find some basic but useful information further down the page. 


How can we help you with GPR?

You can rely on our expert Gender Pay Reporting team to assist with any and all part of Gender Pay reporting. We can advise on whether an organisation has a mandatory Gender Pay Reporting requirement, which data should and should not be included in reporting, accurately process the information and help prepare the narrative that accompanies your report.

We will also verify your own processes and information to ensure that they are compliant and accurate. Finally, we can support you in implementing the policies that will address any gender pay gap.

Failing to accurately report Gender Pay information has resulted in ‘naming and shaming’ by the Government Equalities Office, whilst failing to address the Gender Pay gap in your business can potentially damage your reputation and adversely impact your recruitment and retention.

When is the deadline for Gender Pay reporting? And which organisations need to report Gender Pay information?

Any organisation that employs 250 or more people on the Snapshot Date of 5 April every year, must submit a Gender Pay Report by 4 April the following year. The report should include only those people employed on the Snapshot Date.

What are the reporting requirements for a Gender Pay report?

The report will include six comparative figures including mean and median hourly pay gap, mean and median bonus gender pay gap. You will also need to provide the proportion of males and females in each pay quartile and the proportion of males and females receiving bonus pay.

How do I submit Gender Pay information and where will it be published?

Your Gender Pay Report must be submitted online at the Government’s gender pay reporting website. The report must also remain available on your organisation’s website for a minimum of three years. Your website is also where you can publish the optional ‘narrative’ that will explain to stakeholders the reasons behind any Gender Pay Gap and what steps you are taking to address it. Our experience is that the narrative can be at least as important as the information in the report. It is worth noting that your report, and those of your competitors, will be publicly available to anyone who wishes to read them. As this potentially includes your employees, we would advise you to consider carefully how you will communicate gender pay figures and the related narrative internally.

How does my business compare to my industry?

Submissions are categorised according to the system used by Companies House. By searching the Government website, you will be able to see how your business compares to others in your sector.

Who is responsible for my company’s Gender Pay Report?

Your Gender Pay Report will need to be signed off by a senior employee, usually a named director or equivalent. However, preparing the report and the accompanying ‘narrative’ may require input from HR, Payroll and reward and even corporate communications.

Who can be excluded from Gender Pay Reporting?

The rules around who can and cannot be excluded from Gender Pay Reporting are relatively complex and understanding both the rules and how to interpret data to give meaningful insights into an employer’s Gender Pay Gap trajectory have become more complex again as a result of the impact of the COVID-19. Part-time employees, contractors, employees on maternity leave, non-binary employees and internationally mobile employees can all be subject to special rules, as can employees who were placed on furlough under the Coronavirus Job Retention Scheme at the relevant Snapshot Date. For full advice on how to handle these situations, please either get in touch or download our brochure.

What can we do about our Gender Pay Gap?

We advise clients to question how current policies may be contributing to the problem. For example, career progression of working women and the impact on the gender pay gap is often referred to as the “motherhood penalty” and so it may be necessary to focus on return-to-work policies for women in your organisation. A deeper analysis of the data and where the gender pay gap sits within an organisation can help determine where energies need to be focussed to eliminate the gap. BDO can provide guidance on the analysis and probable causes of the gender pay gap within your business and on possible solutions, including helping you to build and deliver an effective action plan.

Gender and Ethnicity Pay Reporting are just two of the reporting deadlines that employers need to be aware of for 2022. Read our guidance on how to ensure you have accurate data ready in time to meet all the reporting deadlines: Employers’ Year End 2022.