Writing a gender pay gap report: a guide for employers

The first “snapshot date” for gender pay gap reporting is 5 April 2017, with larger employers having to publish their first gender pay gap report no later than 4 April 2018. We look at what organisations need to consider when writing a gender pay gap report.

Private- and voluntary-sector employers in England, Scotland and Wales with 250 or more employees must calculate their gender pay and gender bonus gaps as they are on 5 April each year.

These organisations then have 12 months in which to publish this information on their website, and on the GOV.UK website, in a prescribed format for all to see.

Similar rules apply to employers in the public sector.

We set out the steps for HR professionals to follow when drafting their gender pay gap report.

1. Explain what the gender pay gap report is and why you must publish it

Employers should introduce their gender pay gap report by explaining that legislation requires them to publish details annually of their gender pay gap.

This should make clear the time period covered by the report – so the first would relate to the snapshot date of 5 April 2017.

• Example gender pay gap report: introduction

2. Highlight the six metrics required by the legislation

Employers should set out the six key metrics that are necessary under the rules on gender pay gap reports. These are:

• the difference in the mean pay of full-pay men and women, expressed as a percentage;
• the difference in the median pay of full-pay men and women, expressed as a percentage;
• the difference in mean bonus pay of men and women, expressed as a percentage;
• the difference in median bonus pay of men and women, expressed as a percentage;
• the proportion of men and women who received bonus pay; and
• the proportion of full-pay men and women in each of four quartile pay bands.

The statement should also confirm that the figures have been reached using the mechanisms that are set out in the gender pay gap reporting legislation.

• Example gender pay gap report: key metrics

3. Focus on the underlying causes of a gender pay gap

There is no legal obligation on employers to publish a narrative explaining their gender pay gap figures.

However, it may be worth adding some commentary to the report, to avoid potential reputational damage of failing to put the figures in context.

For example, an employer’s gender pay gap may be wide because:

• they struggle to recruit women in a traditionally male-dominated industry (for example, science and technology);
• women are more likely than men to have had breaks from work that have affected their career progression;
• women are more likely to work part time, and many of the jobs that are available across the UK on a part-time basis are relatively low paid.

The employer could also highlight the male/female make-up of the four quartile pay bands.

The effect of career breaks and part-time working to look after children may have affected female career progression within the organisation, meaning that the higher-paid bands are made up predominantly of men.

• Example gender pay gap report: underlying causes

4. Explain how the employer’s gender pay gap looks against the wider picture

Employers could use their supporting commentary to explain how their figures compare with the gender pay gap of other organisations within the same sector, or compare with the wider economy.

This could include highlighting that other organisations within the same sector have the same problem.

It’s also worth pointing to the national average (using the Annual Survey of Hours and Earnings figures), which is currently around 18%.

If the employer’s gender pay gap looks good against these other figures, this should be a positive focus for the supporting narrative.

• Example gender pay gap report: wider picture

5. Say what the employer is doing to address its gender pay gap

The employer could use its supporting statement to set out any actions that it is taking, or plans to take, to address its gender pay gap.

Committing to review its policy on bonus payments is one example of an action an organisation could take.

This will be particularly important where there are few mitigating factors to explain a wide gap.

Employers can also explain what other steps they are taking to improve gender diversity. This could involve running initiatives to improve support for women returning from maternity leave, to increase their chances of career progression further down the line.

• Example gender pay gap report: action by employer

6. Have a senior figure sign off on the gender pay gap report

For private- and voluntary-sector employers, the report should conclude with a written statement confirming that the information is accurate.

The statement of accuracy must be signed by a senior figure within the organisation. This could be a director, or the employer could choose to give the statement extra weight by having it approved and signed by the CEO.

This requirement does not apply to public-sector organisations.

• Example gender pay gap report: sign off