What is the Gender Pay Gap Regulation?

The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 came into force in April 2017, and requires all private-sector and voluntary sector employers with 250 or more employees to publish statutory calculations every year showing how large the pay gap is between their male and female employees.

Broadly similar rules apply in the public sector under the Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017.

What do I have to report and where?

Relevant employers must follow the rules in the regulations to calculate the following information:

  • Their mean gender pay gap
  • Their median gender pay gap
  • Their mean bonus gender pay gap
  • Their median bonus gender pay gap
  • Their proportion of males receiving a bonus payment
  • Their proportion of females receiving a bonus payment
  • Their proportion of males and females in each quartile pay band
  • A written statement, authorised by an appropriate senior person, which confirms the accuracy of their calculations. However, this requirement only applies to employers subject to the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

The information must be published on both the employer’s website and on a designated government website. Companies that have reported can be seen on the Governments Gender Pay Gap Reporting viewing Service.

What happens if I do not report?

It is a legal requirement for all relevant employers to publish their gender pay gap information. Failing to do this within one year of the snapshot date is unlawful.

The Equality and Human Rights Commission has the power to enforce any failure to comply with the regulations.

Employers will also run a reputational risk if they fail to publish the information, and in many cases the suspicions behind why an employer failed to publish their gender pay gap could have a negative impact and be far worse than what would have been shown by the report.

What does GPG do?

GPG supports companies who need to comply with the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017. It is a simple to use on-line software solution, delivered via self-service and allows you to upload data into pre-defined csv templates. The solution will process data and output the statutory metrics and produce a compliant report for publishing on your corporate website.

GPG delivers the statutory reports and statistics as a minimum. Additional fields can be included in the data upload (selected by users) to allow a deeper level of analysis beyond the standard figures required for statutory reporting at both Advanced and Premium service levels to help improve your reports and better understand your workforce. Comparative reporting is also available at these two levels.

What if I sign up and want to cancel?

You can cancel your membership at any time. Your membership will remain active and you will be able to continue using GPG until the currently purchased time period has elapsed. Payments are made annually in advance.

What data to I have to upload?

You need to prepare your pay data in the format of our downloadable CSV template. We recommend following our Guide To Getting Started if you are unsure about the type of information that needs to be included.

Which employees should be included?

For the purposes of gender pay reporting under The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, the definition of who counts as an employee is defined as:

  • employees (those with a contract of employment)
  • workers and agency workers (those with a contract to do work or provide services)
  • some self-employed people (where they have to personally perform the work)

Each part time worker will count as one employee for gender pay reporting purposes. If an employer uses job-share arrangements then every employee within a job-share counts as one employee each. So, if two people job-share, they would still count as two employees for gender pay reporting purposes. This is particularly important for employers to be aware of if they are accustomed to handling employee numbers as ‘full time equivalents’ because the obligation to report and the calculations that follow are based on the number of individual employees.

For further guidance please see the Government’s Official Guidelines.

Do I have to report by Legal Entity?

Each UK Legal Entity with at least 250 employees within a group structure must calculate and publish separate reports. However, a group of employers who have all provided separate reports may wish to give an indication of the gender pay gap across their overall organisation. Provided that the legally required calculations are clearly provided, employers can enhance their reports as they wish on a voluntary basis where they consider this informative and appropriate.

GPG supports companies who wish to combine reporting across a number of legal entities.

When should I use the GPG Solution?

For statutory reporting, your figures must be calculated annually using a specific reference date as defined in the legislation. This will always be March 31st for public authorities subject to the Specific Duties Regulations, and April 5th for all other employers, in any year where an employer has 250 or more employees. You are legally obliged to publish your gender pay gap figures within a year of this date, and ensure the figures are publicly accessible for at least three years.

You are welcome to use the application to run calculations on data captured outside these dates, for instance should you wish to monitor the effectiveness of equality measures on a quarterly basis; though these reports could not be used for statutory purposes.

Can I compare my data with other employers?

You can see the data of all companies that have reported through the Government's Gender Pay Gap Viewing Service. GPG’s report comparison functionality offers the ability to benchmark against those companies that have reported.

What are the next steps after completing a report?

Once you have completed your statutory calculations with GPG you need to submit your benchmark data on the Government website. You also need to make these available (with a narrative) on your own website. You can use the report generated from GPG for this purpose.

You can continue to use GPG to monitor the progress of your GPG metrics over time by comparing data sets, and receive visual breakdowns of trends that you can export and use to formulate action plans.

What additional support do you provide?


We have been at the forefront of equal and gender pay developments for many years and have the experience and track record of helping organisations navigate through this complex and sensitive area. Our experience began with the conduct of mass equal pay litigation facing the public sector including precedent appeal decisions in the Employment Appeal Tribunal and the Court of Appeal. More recently we were instructed in one of the most high profile equal pay matters when we conducted the BBC Equal Pay Audit. In the lead up to gender pay gap reporting we assisted many employers to navigate their way through the technical detail of the Regulations and prepare their voluntary narrative to accompany their statistics.


Gender pay gap reporting: advising on the duty to report, analysing pay data, assisting with internal and external communications

Root cause analysis: helping organisations to understand the causes underlying their gender pay gaps

Training: providing unconscious bias and diversity training

Recruitment, promotion and senior diversity advice: supporting gender-neutral hiring, appraisal, promotion, mentoring, talent development practices and advising on positive action

Building inclusive workplaces: advising on how to make flexible working, maternity leave, parental leave, career break, reward and other policies more inclusive in practice

Global gender pay reviews: advising multinational employers conducting global gender pay reviews on cultural sensitivities, privacy, confidentiality and labour relation issues

Equal pay risks: gender pay data may reveal potential unlawful pay inequality between men and women and may lead to equal pay claims. We undertake risk reviews, equal pay audits and provide mitigation advice

Do I need to add a voluntary narrative?

Although adding a narrative to the government website is voluntary, it is an opportunity to position and explain your gender pay gap figures. The narrative is your opportunity to position the gender pay conversation, compare and contrast against national or industry data and explain any specifics of your data . It’s also a place where you can share what you’ve done to date, and your future commitments, to promote diversity.  Adding a narrative shows  that you are not only complying with the regulations but embracing the challenges. This will be important to your current and future employees and your customers.

What about data privacy?

Please see our data privacy policy for more information.

Still Unsure?

If you are unsure how the Eversheds Sutherland Gender Pay reporting solution can help your organisation please feel free to get in touch.

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