HM Insights

Less than a month to go: dealing with the Gender Pay Gap Reporting deadline

As the deadline for private sector businesses with 250 or more employees to report on their gender pay gap is fast approaching, here is a quick recap on what is required.

In a nutshell:


The Gender Pay Gap Reporting Regulations (GPGR) came into force in April 2017 and require affected employers to report by no later than 4th April 2018.

Gender Pay Gap Reporting Employment Law Rules Scotland


Private and third sector employers with 250 or more members of staff as at 5th April in each year (different rules apply to public sector organisations)


The GPGR are designed to increase transparency around pay differences between males and females in the workplace. The regulations do not show whether a pay regime in a workplace is unlawful. GPGR is concerned with the statistical differences in pay between males and females averaged out across an organisation, at a particular point in time and no matter what roles people have within the organisation.

What actions do I need to take for Gender Pay Gap Reporting?

Employers must perform certain statutory calculations and publically report the results of these. Gender pay reporting is different from an equal pay audit which focuses on pay between men and women doing the same or similar job, or work of equal value. Paying someone less only because of their gender when the roles are the same is unlawful.

The statutory information needs to be published on the employer’s website as well as uploaded to a Government sponsored site -

Employers need to act now, if they haven't done so already, to:

  • perform the necessary statutory calculations;
  • analyse the data produced by reports;
  • ensure that they meet the reporting deadline; and
  • decide on any appropriate steps to take if issues are identified.

What if we don’t take action?

Although there is currently no financial penalty for failing to comply with reporting, employers could suffer significant reputational consequences if they fail to comply, both internally (from the workforce) and externally (from multiple stakeholders, the press and public alike).

Get in touch

What we can do for you? Getting it right is important – we can ensure your calculation methods and statistical approach is correct in terms of the GPGR. We can help analyse the results and identify any trends and frame narratives that may arise from or around the results. We can also talk about whether the results suggest that risk may arise in pay setting and whether suitable steps should be taken to change pay structures or decision-making processes.

If you want to find out about your reporting obligations or the Gender Pay Gap Regulations, or require assistance in dealing with the publishable information, then please get in touch.