Gender pay gap reporting

An employer in Great Britain with 250 or more employees on its snapshot date must calculate six gender pay gap measures, publish them on its own website and report them on the government’s gender pay gap service within 12 months. For private and voluntary sector employers the snapshot date is 5 April and the deadline is 4 April the following year; most public authorities use 31 March and 30 March.

Which employers have to report?

The duty sits in the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, SI 2017/172. Regulation 1 defines a “relevant employer” as an employer with 250 or more employees on the snapshot date. If the headcount is 250 or more on that date, the employer must report for that year; if it is 249, it has no duty that year, even if it had 300 staff a month earlier.

The test is applied to each legal entity separately. A group with a parent company and three trading subsidiaries looks at each company’s own headcount, and must report separately for every entity that reaches 250. The government guidance allows a group that has reported for each entity to publish combined group figures as well, but the combined figures do not replace the entity returns.

The guidance applies to England, Scotland and Wales. Public authorities in Scotland and Wales have their own rules, and Northern Ireland is outside this regime, although an employer based in Northern Ireland with 250 or more employees working in Great Britain may have to include them.

How is the 250 headcount worked out?

Headcount is the number of individuals, not full time equivalents. GOV.UK guidance says to include:

• everyone with a contract of employment, including part time staff, job sharers and people on leave (two job sharers count as two);
• some self employed people, where they must perform the work personally and cannot subcontract it;
• salaried partners, and LLP members treated as employees for payroll, when counting heads, although they are then left out of the pay calculations;
• apprentices, seasonal, temporary and zero hours workers who are employees on the snapshot date, however short their service.

Agency workers count towards the agency’s headcount, not the hirer’s. Equity partners in traditional partnerships and LLP members who share profits are excluded altogether, because profit shares are not comparable with pay. Where an employer runs more than one payroll, the data must be merged and one set of figures reported.

What are the snapshot date and the reporting deadline?

Regulation 1 sets the snapshot date as 5 April. Employers within the public sector equality duty regulations use 31 March instead. The guidance groups them like this:

Type of employer	Snapshot date	Deadline
Private companies, LLPs, charities, independent schools and other non public authority employers	5 April	4 April the following year
Most public authorities, such as government departments, local authorities, NHS bodies, universities and most schools	31 March	30 March the following year

Regulation 2(2) requires publication within the period of 12 months beginning with the snapshot date. So a private company with 250 employees on 5 April 2026 must publish its 2026 figures by 4 April 2027.

What are the six measures?

Regulation 2(1) lists six items. In the order the guidance calculates them:

1. Pay quarters. The proportions of male and female full pay relevant employees in each of four equal pay bands: lower, lower middle, upper middle and upper.
2. Mean hourly pay gap. The difference between men’s and women’s mean hourly pay, as a percentage of men’s mean.
3. Median hourly pay gap. The same comparison using the median.
4. Proportion receiving a bonus. The percentage of men and the percentage of women who received bonus pay in the 12 months ending on the snapshot date.
5. Mean bonus gap. The difference between the mean bonus paid to men and to women, among those who received a bonus.
6. Median bonus gap. The same comparison using the median bonus.

Figures may be given as whole percentages or to one decimal place. A positive figure means women’s pay or bonuses are lower; a negative figure means men’s are lower.

Which employees go into each calculation?

There are two populations, and mixing them up is the most common technical error.

• Relevant employees are everyone employed on the snapshot date. They are used for the three bonus measures.
• Full pay relevant employees are those paid their usual full basic pay, including paid holiday, in the pay period containing the snapshot date. Anyone on reduced or nil pay because of leave, such as sick leave or family leave paid at a lower rate, is excluded from the hourly pay measures and the quarters, but stays in the bonus measures.

The pay period is the one in which the snapshot date falls. For a company paying monthly on the 1st with a 5 April snapshot date, the guidance example uses the period 1 April to 30 April.

What counts as ordinary pay and bonus pay?

Ordinary pay includes basic pay, allowances and pay for leave, and is taken after any salary sacrifice reduction. It excludes overtime pay, allowances earned during overtime, and benefits in kind such as company cars or private medical insurance. Only amounts actually paid in the relevant pay period count, so arrears for an earlier period are left out. Bonus pay for the bonus measures is everything paid as bonus in the 12 months to the snapshot date. Employers who use salary sacrifice or provide benefits in kind should check their payroll export treats these the way the guidance requires, because a standard gross pay report will not.

How does the calculation work in practice?

Illustration only. A company has 260 employees on 5 April. Eight are on maternity leave at statutory rates and two are on reduced sick pay, so there are 250 full pay relevant employees for the hourly pay measures and 260 relevant employees for the bonus measures.

• Men’s mean hourly pay is £20.00 and women’s is £18.00. The mean gap is (20 minus 18) divided by 20, multiplied by 100, which is 10%.
• Sorted from highest to lowest hourly pay, the 250 full pay employees split into four quarters. Because 250 does not divide by four, the guidance places the two leftover employees one in the lower quarter and one in the upper middle quarter, giving quarters of 62, 63, 62 and 63.
• For bonuses, if 40 of 130 men and 26 of 130 women were paid a bonus in the year, the proportions are 30.8% and 20.0%.

What has to be published, and who signs it?

Regulation 15 requires the figures to be published on the employer’s own website, accessible to employees and the public, for at least three years, and also on the government’s gender pay gap service. GOV.UK says an employer without a website can use its intranet or its parent company’s website.

Regulation 14 requires a written statement confirming the information is accurate, signed by:

• a director, or equivalent, for a company;
• a designated member for an LLP;
• a general partner for a limited partnership, or a partner for any other partnership;
• the most senior employee for any other type of body.

The name and job title of the signatory go on the government service. A supporting narrative explaining the figures is optional. The guidance also describes voluntary action plans that employers can publish now, and says that, subject to legislation, these will become mandatory from spring 2027.

What happens if an employer reports late or gets it wrong?

The guidance states that failing to report by the deadline is against the law, and that the Equality and Human Rights Commission may take enforcement action for late or inaccurate reporting, which can lead to court orders and fines. Employers that miss the deadline also receive a public “late” badge on the gender pay gap service. If headcount falls below 250, the employer should update its reporting requirement on the service so that it does not attract a late badge for a year in which it was not in scope.

Responsibility for accuracy stays with the employer even if a payroll bureau or accountant runs the numbers. The government team will not give case by case advice on interpreting the regulations, so professional advisers are often asked to review the method.

What mistakes come up most often?

• Counting full time equivalents instead of individuals, and wrongly concluding the employer is below 250.
• Reporting group figures only, when each legal entity with 250 or more employees must report.
• Using the full pay population for the bonus measures, or the relevant employee population for the hourly pay measures.
• Including overtime or benefits in kind in ordinary pay, or using pay before salary sacrifice.
• Publishing on the government service but not on the employer’s own website, or removing earlier years before three years have passed.
• Having the statement signed by a finance manager who is not a director.

Gender pay gap reporting is different from equal pay, which concerns paying men and women the same for equal work. Employers in scope also usually have wider reporting duties to check, such as a modern slavery statement and the directors’ report disclosures about employees, and the routine payroll year end tasks fall at almost the same time as the April snapshot.

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Related Accountapedia entries

• Payment practices reporting
• Holiday pay for irregular hours and part year workers
• Written statement of employment particulars
• Partnership, LLP or limited company
• Annual filing calendar for a small limited company

Sources

• legislation.gov.uk: SI 2017/172, regulation 1
• legislation.gov.uk: SI 2017/172, regulation 2
• legislation.gov.uk: SI 2017/172, regulation 14
• legislation.gov.uk: SI 2017/172, regulation 15
• GOV.UK: When to report
• GOV.UK: Who needs to report
• GOV.UK: Making your calculations
• GOV.UK: Preparing your data
• GOV.UK: Overview

Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.