Gender pay reporting – where are you up to?

Gender pay reporting – where are you up to?

So, you’ve identified that you had at least 250 employees as at 5 April 2017 so have to comply with the gender pay reporting requirements – good start!

You’ve preserved your pay data for the pay period including 5 April 2017 – perfect!

You’ve got your head around what counts as ‘ordinary pay’ and ‘bonus’ – excellent!

You’ve done your calculations and worked out your gender pay gap figures – great stuff!

So, job done!  Or, is it?

If you have completed these steps you may well not be looking at an attractive set of statistics. But, you will need to get them published.  You have until 4 April 2018 to do this, but you may not be keen on pressing ‘send’ and making this information public any time soon.  You’re not alone.  Many companies have taken the view that the timing of publication is a tactical decision and they are not eager to be among the first to put their information out there. At the time of writing, only 10 employers’ GPG data appears on the designated government website (

There are things that you can do to reduce the pain of putting your data out there.  The main tool at your disposal is the supporting narrative.  Although this is not an obligatory requirement, ACAS recommends that all employers produce one.  70% of the companies whose GPG data is already on the designated government website have done so on their own websites.  You can use the supporting narrative to confirm your commitment to equal opportunities and to explain why your figures aren’t as bad as they may appear at first sight.

Some of the information that you may wish to include in your supporting narrative is information that is publicly available about other gender pay gaps (‘GPGs’) – maybe the overall national GPG (which stood at 18.1% as at April 2016), industry specific GPGs, regional GPGs or those already published by competitors.  Consider including explanations about the causes of your own GPGs, such as women being underrepresented at a senior level and measures that you have taken to improve your future GPGs, such as steps to encourage female participation in certain industries.

This can be invaluable in preventing your GPG data from deterring potential female employees from showing interest in your business. You need to be careful though not to reveal any damaging information, not to over-promise for the future and not to appear to be engaging in a ‘spin’ exercise.

Analysis Legal can assist with any stage of your gender pay reporting process – get in touch 0161 667 6100 or for a quote.

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