Gender Pay Gap Reporting (UK)

A UK legal requirement under the Equality Act 2010 for employers with 250 or more employees to annually calculate and publish six metrics showing the pay and bonus gap between male and female employees.

What Is Gender Pay Gap Reporting in the UK?

Key Takeaways

  • ✓UK employers with 250+ employees must publish six pay gap metrics annually, covering hourly pay differences, bonus differences, and pay distribution by quartile.
  • ✓The requirement came into force in April 2017 under regulations made through the Equality Act 2010.
  • ✓Around 10,800 employers reported in the 2023/24 cycle, covering roughly 15 million employees.
  • ✓The UK's overall median gender pay gap is 14.3% (ONS, 2024), meaning women earn 85.7p for every 1 pound men earn.
  • ✓Reports are published on a government portal (gender-pay-gap.service.gov.uk) and must also appear on the employer's own website.

Gender pay gap reporting is a UK legal requirement that compels employers with 250 or more employees to measure and publish the pay difference between their male and female staff. It was introduced through The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 and applies to private and voluntary sector employers (reporting deadline: 4 April each year) and public sector employers (reporting deadline: 30 March each year). The regulations don't require employers to eliminate their gap or take specific corrective action. They require transparency. The theory is that publishing the numbers creates accountability, media scrutiny, and employee pressure that motivates organizations to act. That theory has been partially validated: the largest gaps have narrowed since reporting began, though progress has been uneven. Gender pay gap reporting measures the difference in average pay between all men and all women in the organization. It's not an equal pay audit (which compares pay for the same role). A company can have a zero equal pay gap and a 30% gender pay gap if nearly all its senior, high-paying roles are held by men.

~10,800Employers filed gender pay gap reports in the UK for the 2023/24 reporting cycle (GOV.UK)
14.3%UK median gender pay gap across all reporting employers (ONS, 2024)
6 metricsRequired statistics: mean/median hourly pay gap, mean/median bonus gap, bonus proportions, pay quartiles
April 4Snapshot date for private sector employers (5 April for public sector)

The Six Required Metrics

Every reporting employer must calculate and publish six specific figures based on a snapshot date (5 April for private sector, 31 March for public sector).

1. Mean gender pay gap in hourly pay

The difference between the average hourly rate of pay for men and the average hourly rate for women, expressed as a percentage of men's pay. Mean figures are influenced by outliers: a few very highly paid male executives can significantly increase this number. Formula: (Mean male hourly pay minus Mean female hourly pay) / Mean male hourly pay x 100.

2. Median gender pay gap in hourly pay

The difference between the median (middle) hourly rate for men and the median hourly rate for women. This is generally considered the more reliable measure because it isn't skewed by extreme values. The UK national median gap is 14.3% as of 2024. If a company's median gap is significantly above this, it indicates a worse-than-average distribution problem.

3. Mean bonus gap

The difference between the mean bonus paid to men and the mean bonus paid to women over the 12 months preceding the snapshot date. This figure can be very large (30%+) in industries like financial services where bonus pools are substantial and disproportionately allocated to senior roles (which are disproportionately held by men). The bonus gap is often the most eye-catching number in a company's report.

4. Median bonus gap

The difference between the median bonus paid to men and the median bonus paid to women. Like the median pay gap, this is less affected by extreme values. If a company pays small bonuses to many women (in lower-graded roles) and large bonuses to fewer men (in senior roles), the median bonus gap may be smaller than the mean bonus gap but still significant.

5. Proportion of males and females receiving a bonus

The percentage of men and the percentage of women who received any bonus during the 12-month period. A company might have equal bonus proportions (80% of men and 80% of women received bonuses) but still have a large bonus gap because men's bonuses were much larger. Alternatively, unequal proportions (90% of men vs 60% of women) suggest that bonus eligibility criteria or employment patterns are gendered.

6. Pay quartile distribution

All employees are ranked by hourly pay from lowest to highest and divided into four equal quartiles. The employer must report the percentage of men and women in each quartile. This is the most revealing metric. A company with 70% women in the lower quartile and 80% men in the upper quartile has a structural representation problem, not just a pay gap. The quartile distribution explains why the gap exists and where action is needed.

How to Calculate UK Gender Pay Gap Figures

The calculation methodology is prescribed by the regulations. Getting it right requires careful handling of employee data.

Who counts as a "relevant employee"?

All employees, workers, and some agency workers who are employed on the snapshot date (5 April or 31 March) and who are paid their usual rate of pay during the relevant pay period. Employees on reduced pay (sick leave, maternity leave with statutory pay only) are excluded from the hourly pay calculations but included in the headcount. Partners in LLPs count. Self-employed contractors do not. The employer must determine each person's gender: this should come from HR records and employees should be asked to self-identify where records are ambiguous.

Calculating hourly pay

Hourly pay includes base pay, allowances, shift premiums, pay for piecework, and pay for leave. It excludes overtime pay, redundancy pay, pay in lieu of leave, benefits in kind, and salary sacrifice deductions (these reduce gross pay but are reinstated for gender pay gap calculations). For salaried employees, divide the relevant pay period's gross pay by the number of working hours in that period. For hourly workers, use the actual hourly rate multiplied by basic hours. ACAS provides detailed technical guidance on edge cases.

Bonus calculations

Bonus pay includes profit sharing, productivity bonuses, commission payments, and payments linked to performance, but not overtime pay, redundancy payments, or pay in lieu of notice. The bonus period covers the 12 months ending on the snapshot date. Long-term incentive plans (LTIPs) that vest during this period are included. Share options exercised during the period are included at the gain value. This means a single executive exercising stock options can dramatically skew the mean bonus gap.

Publishing and Compliance Requirements

Employers must publish their data in two places and meet strict deadlines.

Government reporting portal

All six metrics must be uploaded to the government's gender pay gap reporting service (gender-pay-gap.service.gov.uk). The portal is publicly searchable: anyone can look up any reporting employer's figures. Data is archived, so year-on-year trends are visible. The deadline is 4 April for private/voluntary sector employers and 30 March for public sector employers. Late reporting is noted on the portal and can trigger enforcement action.

Employer's own website

Employers must also publish the data on their own website, accessible to both employees and the public. Many employers accompany the data with a narrative explaining the gap and outlining actions they're taking. This narrative is optional but strongly recommended. Raw numbers without context invite misinterpretation by media and employees.

Enforcement

The Equality and Human Rights Commission (EHRC) is responsible for enforcement. Employers who fail to report can be investigated, named publicly, and ultimately face court orders and unlimited fines. In practice, enforcement has been measured: the EHRC focuses on late reporters and non-reporters rather than prosecuting employers with large gaps. Reporting was suspended during 2019/20 due to COVID-19 but resumed for the 2020/21 cycle. Compliance rates are high: over 99% of eligible employers report by the deadline.

Has UK Gender Pay Gap Reporting Worked?

After seven years of mandatory reporting, the evidence on effectiveness is mixed but leans positive.

What's improved

The median gender pay gap has decreased from 18.4% in 2017 to 14.3% in 2024 (ONS data). Employers with the largest initial gaps have shown the most improvement. FTSE 100 companies have increased the proportion of women on boards from 27% in 2017 to 40% in 2024. Job applications to companies with published large gaps decreased by 7%, creating a recruitment incentive to act (research from Harvard Business School). The biggest impact may be cultural: gender pay has moved from a niche HR topic to a boardroom and media priority.

What hasn't changed

Progress has been slow: 4.1 percentage points in 7 years at the national level. Some industries (construction, finance) have barely moved. 8% of employers reported wider gaps in 2024 than in 2017. The requirement to report doesn't include a requirement to act. Many employers publish the numbers, add a boilerplate narrative about being committed to diversity, and take no meaningful action. The EHRC lacks resources for proactive enforcement beyond compliance monitoring. Ethnicity pay gap reporting hasn't been mandated despite being recommended by the 2017 McGregor-Smith Review.

4.1pp
Reduction in UK median gender pay gap since mandatory reporting began (2017 to 2024)ONS, 2024
40%
Women on FTSE 100 boards in 2024, up from 27% in 2017FTSE Women Leaders Review
7%
Reduction in job applications to employers with large published pay gapsHarvard Business School
8%
Of employers with wider gaps in 2024 than their first report in 2017/18Gender Pay Gap Service

Writing an Effective Gender Pay Gap Action Plan

Publishing numbers without a plan to improve them is a missed opportunity. The best action plans follow a clear structure.

Diagnose the root cause

Don't guess why the gap exists. Analyze the quartile data: where are women concentrated? Look at hiring data: are women being recruited into lower-graded roles? Examine promotion rates: are women being promoted at the same rate as men? Check starting salaries: are women offered less for the same role? The diagnosis determines the intervention. An employer with a gap caused by underrepresentation of women in senior technical roles needs a different strategy than one with a gap caused by lower starting offers.

Set measurable targets

"We are committed to closing the gap" isn't a target. "We will reduce our median pay gap from 18% to 14% within three years by increasing female representation in upper-quartile roles from 35% to 45%" is a target. Tie targets to executive accountability and compensation. What gets measured and rewarded gets done.

Common high-impact actions

Review and standardize starting salary practices (eliminate gender-correlated negotiation outcomes). Introduce returnship programs for women re-entering the workforce after career breaks. Set representation targets for shortlists and interview panels. Offer enhanced shared parental leave and actively encourage uptake by men. Invest in sponsorship programs that connect high-potential women with senior leaders who advocate for their advancement. Review role models and marketing materials for unconscious bias signals.

Common Mistakes in UK Gender Pay Gap Reporting

Errors in calculation or communication can undermine the entire exercise.

  • Including overtime in hourly pay calculations (it should be excluded).
  • Failing to add back salary sacrifice deductions (pension, cycle-to-work schemes) to gross pay before calculating hourly rates.
  • Counting employees on reduced pay (maternity/paternity leave at statutory rates) in the hourly pay analysis instead of excluding them.
  • Confusing the gender pay gap with equal pay: the narrative explaining a 20% gap shouldn't claim "we pay men and women equally for the same role" because that's a different analysis.
  • Submitting data late and assuming there are no consequences: the EHRC has increased enforcement activity since 2022.
  • Writing action plans with vague commitments and no measurable targets or timelines.
  • Ignoring the bonus gap: this is often the largest and most actionable metric, especially in sales and finance-heavy organizations.

Future of UK Pay Gap Reporting

The UK's reporting framework is likely to expand in scope and rigor over the coming years.

Ethnicity pay gap reporting

Voluntary ethnicity pay gap reporting has been growing: 19% of FTSE 100 companies published ethnicity pay data in 2024. Mandatory ethnicity pay gap reporting has been debated since the 2017 McGregor-Smith Review recommended it. The main challenges are smaller sample sizes within ethnic groups (requiring careful aggregation to protect anonymity) and the complexity of ethnic categorization. Many expect mandatory ethnicity pay reporting within the next 2 to 3 years.

Mandatory action plans

The current requirement to report without a requirement to act is the system's biggest weakness. There's growing political and academic support for mandating that employers publish an action plan alongside their data, similar to France's approach where employers scoring below a threshold must publish corrective measures or face fines. The EU Pay Transparency Directive (which doesn't apply to the UK post-Brexit but sets a precedent) requires joint assessments and remediation when gaps exceed 5%.

Lowering the threshold

The 250-employee threshold excludes the majority of UK employers. Germany's threshold is 500 employees (with some provisions at 200). France's is 50. Lowering the UK threshold to 50 or 100 employees would significantly expand coverage. The challenge is administrative burden on smaller employers, but payroll software increasingly automates the calculations.

Frequently Asked Questions

What's the deadline for submitting gender pay gap data?

Private and voluntary sector employers must report by 4 April each year, using a snapshot date of 5 April of the previous year. Public sector employers must report by 30 March, using a snapshot date of 31 March of the previous year. For example, the 2024/25 reporting cycle uses a 5 April 2024 snapshot date with data due by 4 April 2025.

What happens if we don't report?

The EHRC can investigate non-compliant employers, issue unlawful act notices, and seek court orders requiring compliance. Ultimately, non-compliance can result in unlimited fines. More immediately, failure to report is publicly visible on the government portal, creating reputational risk. Media organizations regularly publish lists of non-reporters. Since 2022, the EHRC has become more active in enforcement, contacting late reporters directly.

Do we have to include part-time workers?

Yes. All employees, including part-time workers, must be included. Their hourly pay rate is calculated the same way as full-time workers. Since women are significantly more likely to work part-time, excluding them would distort the figures. The Regulations specifically require inclusion of all workers on the snapshot date who received their usual pay.

Is the gender pay gap the same as unequal pay?

No. Unequal pay means paying men and women differently for the same or equivalent work, which is illegal under the Equality Act 2010. The gender pay gap is the difference in average pay across all roles. A company can pay men and women identically in every role and still have a gap if men dominate higher-paid positions. Both are problems, but they have different causes and different solutions.

Can companies be penalized for having a large gender pay gap?

No. There's no penalty for the size of the gap, only for failing to report. Employers with 50% gaps are treated the same as employers with 2% gaps under the current regulations. This is the most common criticism of the system. The requirement creates transparency, not accountability for outcomes. The EU Pay Transparency Directive takes a stronger approach by requiring corrective action for gaps over 5%.

Should we include a narrative with our data?

It's not legally required, but it's strongly recommended by ACAS, the EHRC, and the Government Equalities Office. Raw numbers without context are easily misinterpreted. A good narrative explains why the gap exists (typically related to workforce composition), what the organization is doing to address it, and what progress has been made since the previous report. The narrative is your opportunity to control the story before journalists or employees tell it for you.
Adithyan RKWritten by Adithyan RK
Surya N
Fact-checked by Surya N
Published on: 25 Mar 2026Last updated:
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