UK gender pay gap reporting requirements apply to any employer with 250 or more employees on the annual snapshot date. Those employers must produce six specified pay calculations from their payroll data, publish the figures on the government’s gender pay gap service alongside a signed written statement, and post the same figures on their own website. Miss the deadline and the Equality and Human Rights Commission can escalate from a warning through to court proceedings that carry an unlimited fine.
Who Has to Report
The obligation is triggered by headcount on one specific day. For private and voluntary sector employers, that day is 5 April. For most public authorities, it is 31 March.1GOV.UK. Gender Pay Gap Reporting: When to Report If you had 250 or more employees on that date, you must report for that reporting year.
The 250 threshold comes from the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, which define a “relevant employer” as one with 250 or more employees on the snapshot date.2Legislation.gov.uk. The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 The count picks up everyone with a contract of employment, including part-time staff and employees on leave. Fluctuations across the year don’t matter. If your headcount was 300 in February and 240 by June, only the number on 5 April (or 31 March) decides whether you are in scope.
The requirement reaches a wide range of organisations: companies, charities, limited liability partnerships, and government-funded bodies among them.
The Six Required Calculations
The reporting service is built around six figures, and every in-scope employer submits all six.3GOV.UK. Making Your Calculations
- Mean hourly pay gap. Add up the hourly rates for men and divide by the number of men; do the same for women. Subtract the women’s average from the men’s, divide by the men’s average, multiply by 100.
- Median hourly pay gap. Line up men from lowest to highest hourly pay and find the middle value. Repeat for women. Express the difference as a percentage of the men’s median.
- Mean bonus pay gap. The same averaging logic applied to bonus payments over the 12 months ending on the snapshot date.
- Median bonus pay gap. The midpoint comparison applied to bonus payments over the same 12-month window.
- Proportion receiving bonuses. The percentage of men, and the percentage of women, who received any bonus pay during that 12 months.
- Pay quartiles. Rank the whole workforce from lowest to highest hourly pay, split into four equal groups, and report the percentage of men and women in each quarter.
The two time windows behind these figures are different, and mixing them up is a common error. The hourly pay calculations use pay in the pay period that includes the snapshot date. The bonus calculations use a full 12-month period ending on the snapshot date.
What Counts as Pay
The regulations separate “ordinary pay” from “bonus pay,” and each feeds different calculations.
Ordinary pay includes basic pay, allowances such as location payments or recruitment and retention supplements, piecework pay, pay for leave, and shift premium pay. It excludes overtime pay, redundancy or termination payments, pay in lieu of leave, and anything paid in a form other than money.2Legislation.gov.uk. The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017
Bonus pay covers remuneration linked to profit sharing, productivity, performance, incentives, or commission, whether paid in cash, vouchers, or securities. It does not include ordinary pay, overtime, or termination-related payments.2Legislation.gov.uk. The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017
Deadlines and How to Submit
The reporting deadlines sit just short of a full year after the snapshot date. Private and voluntary sector employers must publish by 4 April. Most public authorities must publish by 30 March.1GOV.UK. Gender Pay Gap Reporting: When to Report
The six calculations go on the government’s gender pay gap service, which is a searchable public database.4Gender pay gap service. Gender Pay Gap Service The submission must include a written statement confirming that the figures are accurate. Who signs depends on the organisation’s legal form:
- Company: a director.
- Limited liability partnership: a designated member.
- Other partnership: a partner.
- Unincorporated body: a member of the governing body or a senior officer.5Legislation.gov.uk. a href=”https://www.legislation.gov.uk/ukdsi/2017/9780111152010″ target=”_blank” rel=”noopener”>The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017
Publication on the government service is not the whole job. You also have to publish the same data on your own public-facing website, where it must stay accessible for at least three years.6Equality and Human Rights Commission. Step 3: Publish Your Gender Pay Gap Report If you don’t run a public website, publish on an intranet or parent company site and make sure employees know where to find the figures.
Narrative and the Coming Action Plan Requirement
There is no legal requirement at present to publish a narrative alongside the numbers, though the government strongly encourages it. A narrative lets you explain what is driving your gap and what you plan to do about it.
That position is set to change. Subject to legislation, action plans are due to become mandatory from spring 2027, and will need to set out concrete steps to address the organisation’s gender pay gap.7GOV.UK. Gender Pay Gap Reporting and Creating an Action Plan Employers producing voluntary action plans now will be ahead when the requirement takes effect.
What the Required Figures Do Not Show
The mandatory calculations produce an “unadjusted” or “uncontrolled” pay gap: the raw difference in average earnings between men and women across the whole workforce. They make no allowance for job role, seniority, qualifications, working hours, or location. An organisation where women are concentrated in junior or part-time roles will show a large gap even if men and women in identical positions are paid the same.
Nothing in the regulations stops you from also publishing an “adjusted” analysis that controls for variables like job level, experience, and working pattern. That is a supplement, not a substitute. The six required figures still have to be submitted as specified.
Enforcement
The Equality and Human Rights Commission enforces the reporting duty through a graduated process, and it monitors the government database to identify employers who have missed the deadline.8Equality and Human Rights Commission. Gender Pay Gap: Our Enforcement Action
The first step is a warning notice telling the organisation to report. If the employer still doesn’t comply, the EHRC may open a formal investigation to establish whether the regulations have been breached. Where a breach is confirmed, the EHRC can issue an “unlawful act notice” requiring the employer to comply and prepare an action plan to avoid future breaches.9Legislation.gov.uk. Equality Act 2006 – Section 21 Public bodies may instead receive a statutory compliance notice.
If an employer ignores those notices, the EHRC can apply for a court order compelling compliance. Breaching that court order is a criminal offence punishable by an unlimited fine.8Equality and Human Rights Commission. Gender Pay Gap: Our Enforcement Action Most employers comply at the warning stage, and few cases progress to court orders. The reporting service is public, though, so non-compliance is visible to anyone looking, including journalists and job applicants.