The Legal 500

Twitter Logo Youtube Circle Icon LinkedIn Icon

Pitmans LLP

Work +44 345 222 9222
Fax +44 118 958 5097

Show all Press releases

Gender Pay Gaps: The Latest Reporting Requirements

July 2016

May 2016

On average, male employees are paid more than female employees. In 2015, men working full-time were paid approximately 9.4% more than women working full-time. As a result, the government is working to introduce measures with the aim of reducing this gap.
The new gender pay gap reporting regime

The government has published new regulations which will introduce mandatory gender pay gap reporting. The requirement only concerns employers with 250 employees or more and aims to increase employee confidence in the remuneration process and also help employers to identify areas in which they need to increase female participation. The government believes that having a consistent measure of the gender pay gap that can be compared across employers and sectors will encourage employers to examine their gender pay data in comparison to the national average and their competitors.
What is required of employers?

From April 2017, employers with over 250 employees will be required to:

    Publish overall gender pay gap figures using both their mean and median figures. The median perhaps gives a better representation of the gap because it is not distorted by a small number of high earners in a particular organisation;
    Report on the number of men and women in their four salary quartiles based on the employer’s overall pay range;
    Publish separate information on the gender pay gap relating to bonuses.

In addition, employers have the option to include an explanation together with their results. This narrative will be beneficial to employers who currently have a large gender pay gap but who intend to take action in the future to improve equality of pay in their workplace.
What is meant by “pay”?

Employers should take into account the following when reporting their gender pay gaps: basic pay, paid leave, maternity pay, sick pay, area allowances, shift premium pay, bonus pay, car allowances and other allowances received through the payroll. Overtime, expenses, redundancy pay and tax credits should not be included. Pay should be calculated using gross figures.
When will employers need to publish their statistics?

Employers will need to report their gender pay gap annually in order to promote transparency and maintain momentum in the need for employers to take action. On 30 April of each year (beginning in 2017), employers with 250 employees or more should take a snapshot of their data relating to pay. Employers will then need to analyse and publish their gender pay gap statistics at any time within 12 months from 30 April. This provides employers with a fair amount of flexibility.

The government estimates that costs incurred by employers in complying with the new requirement will be minimal and will average ÂŁ468 per year per employer.
How should the data be published?

Employers should publish their gender pay gap data on their website and also retain the information themselves for 3 years. The information needs to be disclosed to the government via a government-sponsored website together with a written statement confirming that the information is accurate. The written statement should be signed by a director, a designated member, a partner or the most senior employee of the employer, depending on the type of organisation in question.
How will the government monitor the results?

In order to ensure compliance with the new regulations, the government will:

    Run periodic checks to assess for non-compliance
    Produce tables by sector of employers’ reported gender pay gaps
    Highlight and identify employers who publish particularly detailed results
    Name and shame employers who have not complied.

This means that there is no formal enforcement mechanism in the form of sanctions for employers who fail to comply with the new regulations. The information published does not need to be audited or verified. The only real consequence of non-compliance will be the impact of scrutiny by the public and prospective employees which could lead to reputational damage.
   Mark Symons

Mark is an experienced commercial employment specialist who is Head of the Employment Department which operates out of London Reading and Southampton.
   Angela Shields

Employment disputes, including unfair dismissal, whistle blowing, discrimination and obtaining or defending applications for injunctions in relation to restrictive covenants, confidential information or intellectual property.

- See more at:

Legal Developments in the UK

Legal Developments and updates from the leading lawyers in each jurisdiction. To contribute, send an email request to
  • Gulbenkian Andonain discuss NEW Tier 1 Start-Up Visa and the NEW Tier 1 Innovator Visa

    The document entitled "Statement of Changes to Immigration Rules" which was released by the House of Commons on the 7th March 2019, outlined and advised us on a number of changes that will come into place that will affect the Tier 1 Investor Visa amongst other visa programmes and schemes. The latest article on our website discusses both of these new UK business visa routes. Our immigration lawyers London are already up to date on all of the required information for both the NEW Tier 1 Start-Up Visa and the NEW Tier 1 Innovator Visa .
  • Upcoming Changes to the UK Tier 1 Investor Visa

    According to the new document from the House of Commons on March 7th 2019 titled “Statement of Changes to Immigration Rules”, a number of changes will come into place that affecting the Tier 1 UK Investor Visa programme amongst other visa programmes and schemes.
  • Brexit and non-EU Immigration

    There is no doubt that the UK has to date benefited immensely from visa-free EU immigration to the extent that visa conditions and caps on non-EU migrant have undermined and overshadowed the ability of this group to play a prominent role in British industry and commerce and in its expanding and overburdened NHS service. It is the view of  Gulbenkian Andonian  however, that after  Brexit, there should be a noticeable change in those skilled non-EU migrants contributing to British society in a meaningful way. 
  • Gulbenkian Andonian Solicitors discuss Post Brexit scenarios - EU Nationals and Salient Immigration

    From 1 January 2021 everyone except for British and Irish citizens will be subject to immigration control in the UK.   Gulbenkian Andonian solicitors has already published an article on this topic of post- Brexit immigration and has discussed the case of EU nationals and family members after Brexit, you can find that article here as one of many in our blog .

    Tescoadmitted wrongdoing over its accounting scandal in order to obtain a deferredprosecution agreement and avoid a conviction. But with everyone charged overthe scandal having been cleared, Aziz Rahman examines whether the deferredprosecution agreement process needs revising.

    With Standard Bank having become the first organisation to conclude a DPA, Aziz Rahman explains why gaining one is only the start of the challenge.

    The sacking of Nissan’s high-profile chairman may have beenproof that nobody is infallible. But Nicola Sharp argues that it should also beseen as an indicator that no company can be considered safe from wrongdoing.
  • Applying for A Sole Representative Visa

    Regardless of the Brexit outcome, the United Kingdom will remain one of the world most powerful economies. With a market of 65 million people and close ties with Europe, many overseas-based organisations look to establishing a subsidiary or branch office in Britain.

    Aziz Rahman considers the Ericsson bribery investigation and outlines how best to respond if you are investigated by more than one law enforcement agency
  • Have Changes to The Spouse/Civil Partnership Minimum Income Threshold Made A Difference?

    The plight of those denied a UK Spouse/CivilPartnership Visa or a Spouse/Civil Partnership Visa extension continues to feature in the headlines.   In August 2018, the Guardian reported on one young woman, driven to attempt suicide after her fiancé, an Albanian national, was not permitted to enter the country.   The Home Office ruled Paige Smith, a British Citizen, did not meet the £18,600 income threshold.   It later transpired the Home Office lost a crucial payslip proving that Ms Smith met the criteria, a document the department had been sent four times by a Solicitor and Ms Smith’s MP.   The appeal Judge took ten minutes to rule the Visa should have been approved; however, the couple still had to wait two months for the Home Office to declare it would not appeal the decision.