Gender Pay Gap Reporting 2024

As we approach April 2024, UK businesses must turn their attention to an increasingly relevant issue – the gender pay gap. The need for accurate and timely submissions of gender pay gap data is not just a statutory requirement; it’s a testament to a company’s commitment to proactively taking measures to consider and improve diversity, inclusion and fairness in the workplace.

In today’s world, the gender pay gap remains a significant barrier to equality. Despite advancements in many areas, discrepancies in pay between genders persist, hindering not just individuals, but businesses and the economy overall. A diverse workforce, where everyone is paid fairly, is a more innovative, creative, and productive one. Hence, addressing the gender pay gap is not just ethically right, it’s a practice we would consider commercially astute too.

If you would like to discuss your Gender Pay Gap reporting requirements, you can book a free consultation with a member of our team here.

Gender Pay Gap Reporting Requirements for Employers

The process of gathering and submitting gender pay gap data, however, is far from trivial. It requires meticulous data collection, sorting, and analysis. Payroll software can support with this, but our experience tells us that often the numbers can be more complex to manage than initially expected and shouldn’t be underestimated.

The Gender Pay Gap data must be accurate and submitted on time (by 04th April 2024, and public-sector organisations must report by 31st March 2024); otherwise, running the risk of non-compliance with regulations and potential reputational damage. It can be a time-consuming process, but it’s a necessary one.

Having said all that, it’s important to note that submitting your data is just the initial, surface-level requirement. The real work lies in interpreting the data and crafting a narrative around what it means for your organisation in practice. This narrative is crucial because it provides context for the numbers and can help explain why the gap exists, what steps are being taken to close it, and how it aligns with the company’s broader diversity and inclusion goals. It’s the most visible part of your submission and is likely to be scrutinised by your employees, investors, competitors, media, and the public. So getting it right is essential!

Gender Pay Gap Reporting Guidance

There are numerous resources available for employers who are required to submit a Gender Pay Gap report, but the process is time consuming and can be complex depending on the structure of your organisation.

A brief high-level suggested summary of the steps required for submitting your Gender Pay Gap are noted below:

1. Determine Applicability: The regulations apply to employers in the UK with 250 or more employees. Organisations must complete their report for each separate ‘legal entity’, if you are part of an organisation or group with more than one legal entity. The 2024 reporting deadlines for submitting the gender pay gap report are as follows: 31 March 2024, and 04 April 2024.

2. Gather Data: You should base your gender pay gap calculations on payroll data taken on your snapshot date (which can be confirmed on the gov.uk website). Collect relevant employee data, including the proportion of male and female employees in different pay quartiles.

3. Prepare Your Data: From the data you have gathered, prepare the following:

• Create a list of relevant employees, and a list of full-pay relevant employees
• Add how much ‘ordinary pay’ you paid (full-pay relevant employees only).
• Add how much bonus pay you paid.
• Add employees’ weekly working hours (full-pay relevant employees only).
• Work out your employees’ hourly pay.

4. Calculate Key Metrics: Calculate the following metrics based on the collected data:

• Mean gender pay gap.
• Median gender pay gap.
• Mean bonus gender pay gap.
• Median bonus gender pay gap.
• Proportion of males and females receiving a bonus.

5. Prepare a Written Statement: Provide a written statement signed by an appropriate senior individual, such as a director, confirming the accuracy of the calculations.

6. Prepare Supporting Narrative & Action Plan: This step is not a legislative requirement, but is strongly advised because a supporting narrative and action plan can help people understand why you think you have a gender pay gap and what action you have taken to analyse and close it. Including this step in your Gender Pay Gap reporting process can positively impact an organisation’s reputation.

7. Publish the Gender Pay Gap Report: Publish the report on the company’s website and report to the government via the designated online reporting service.

8. Promote the Report: Ensure that the report is easily accessible to employees and the public. Consider providing a narrative to explain any identified pay gaps and the actions being taken to address them.

9. Review and Update: Regularly review and update the gender pay gap data, at least annually, to track progress and assess the impact of any measures taken to address the gap.

10. Addressing Pay Gaps: Consider implementing strategies to address identified gender pay gaps, such as training, mentoring, and policies promoting equal opportunities.

11. Plan for Next Year’s Report: Establish an end-to-end process with key milestones and deadlines to ensure the organisation’s gender pay gap reporting process can not only tick the legislative requirements of the report but can provide as much value as possible to the organisation. HR and Employment Law specialists can assist with planning and preparing Gender Pay Gap reports, reflections, and action plans.

Gender Pay Gap Service

We understand the complexities and challenges of the gender pay gap submission. We have the expertise and resources to help you navigate this process seamlessly. We can assist with getting your data into the right place, complete the analysis, and also help you craft a compelling narrative to comply with regulations and set you on track to focus your future strategic aims.

The gender pay gap submission due in April 2024 is not just about meeting a legal requirement; it’s an opportunity to reflect on and improve your company’s diversity and inclusion practices. It’s about taking a step towards a more equal and inclusive future and we would be happy to work with your organisation on this together.

If you would like to discuss any aspect of the Gender Pay Gap reporting process, please contact Rachel Coupland or your usual People team contact.