Gender pay gap reporting – don’t forget the deadlines!

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Gender pay gap reports are designed to highlight any differences in the average pay between men and women in an organisation – the idea being if a business is forced to analyse such data, they may go on to identify the root cause of any pay gap and then put a plan of action in place to reduce the gap.

The reports are based on data from a snapshot date each year (31 March or 5 April, depending on whether the business is public or private) with the deadline for reports being submitted to the online government portal by 30 March or 4 April the following year.

For this year, a large private sector employer should submit its report by 4 April 2022 based mainly on data from 5 April 2021.  If a business misses its reporting deadline, the Equality and Human Rights Commission can take action against it.  The business may also face adverse publicity in seemingly ignoring gender pay gap as an issue.

The pandemic saw changes to mandatory reporting requirements.  In 2020 eligible businesses were not required to report at all if they didn’t want to and in 2021, the deadline for reporting was effectively pushed back to 5 October 2021.

2022 though is business as usual and large employers must remember to submit and publish their data on time.

Businesses must remember that most of the analysis focuses on employees receiving full pay – any reduced pay, such as pay during family leave, sick leave or (crucially) time spent on furlough, should not be taken into account for the majority of the calculations.  Any impact this has on pay gaps can be explained however in a supporting narrative. If furloughed employees are skewing the figures, businesses could voluntarily produce additional figures that show what the pay gap would have been had all furloughed employees received full pay on the snapshot date. This may help reassure anyone looking at the figures of the pay gap, had it not been for need to furlough staff.

Our dedicated team of employment law experts can help you with the process, providing you contact us here, before April.