Gender Pay Reporting

25 February 2021

The Government announced this week that gender pay gap reporting enforcement will be delayed by six months in 2021, to allow organisations more time to prepare their reporting figures amongst a busy recovery period from the peak of the COVID-19 pandemic as well as other conflicting deadlines and challenges.

They did however make it clear that companies can and should ideally still submit their figures by the usual April deadline, and it is important that firms’ strategic emphasis should still be on reducing the gender pay gap wherever possible.

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

Organisations now have until 5 October 2021 to submit data before any enforcement action is taken.

The Government previously took the decision to suspend enforcement of the gender pay gap deadlines for reporting year 2019/20, which now means that organisations will have an 18 month lag in calculations.

Baroness Kishwer Falkner, Chair of the Equality and Human Rights Commission, said that the delay “strikes the right balance between supporting businesses and enforcing these important regulations” whilst Matthew Fell, CBI Chief UK Policy Director, said that “reinstating enforcement from October 2021 will ensure that all firms within scope publish their data, while giving those who have been closed for most of the last year more time to do so.”

Organisations may wish to do this for internal purposes anyway, so that you can track progress year on year and to ensure that calculations made in October 2021 are not too onerous or at risk of miscalculation. There may also be added complications with calculations this year due to employees having been entered into the Coronavirus Job Retention Scheme (CJRS).

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. 

Download your guide to Gender Pay Reporting 

How BDO can 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. Part-time employees, contractors, employees on maternity leave, non-binary employees and internationally mobile employees can all be subject to special rules. 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 how to build and deliver an effective action plan.