Skip to content
UK SRSThe UK Sustainability Reporting Standards, ESOS, SECR and TCFD, read against the published text.HUBUK SRS GuideAn independent reference guide to UK SRS, ESG, TCFD, SECR, ESOS and the global standards.YOU ARE HEREGlobal Reporting StandardsSustainability reporting standards worldwide: ISSB, the EU CSRD after Omnibus I, California SB 253 and SB 261, and UK SRS.UK SRS StandardsUK SRS S1 and S2 at the provision: reliefs, comply or explain, and the FCA statements.ESOS QuestESOS Phase 4 in depth: qualification, the audit, sign-off, action plans and penalties, read against the Regulations.SRS EngineeringThe data build behind a UK SRS report: metrics, owners, controls and timing.SRS ReportWhat a UK SRS report contains, how it is assembled, and how to read one.UK SRS ReportAnalysis and commentary: CDP, the DESNZ emission factors, SECR and ESOS, with every figure cited.UK SRS NewsThe cluster's news publication, and what a UK SRS report contains.UK SRS DeliveryTemplates, costs, ESOS delivery guides and readiness assessment.UK SRS FinanceFinanced emissions, PCAF and IFRS S1/S2 for banks, insurers and asset managers.SECRStreamlined Energy and Carbon Reporting: deadlines, thresholds, eligibility and guidance.Carbon CreditsCarbon credit ratings, risk analysis, valuation and market structure.Environmental RegimesThe eight UK environmental reporting regimes, their thresholds, deadlines and regulators.UK SRS ServicesThe services arm: ESOS, SECR, net zero and sustainability consultancy.

Standards and reporting

Gender Pay Gap Reporting

Gender pay gap reporting needs a defined employer and snapshot population before calculation, because a technically correct spreadsheet can still describe the wrong people or pay period.

What does gender pay gap reporting involve?

Relevant employers publish prescribed pay-gap information under the applicable regulations, with different private/voluntary and public-authority routes SI 2017/172 SI 2017/353.

Define the reporting employerRequirements and evidence

Module 01 / 04

Employer

Identify the organisation subject to the reporting assessment.

Read the detailed guidance and evidence

The work is not complete merely because payroll software produces a difference between two averages.

The standards overview places this statutory output alongside broader sustainability reporting, while ESRS S1 addresses a separate own-workforce disclosure task.

Which scope decisions should be recorded first?

Avoid applying one employer threshold or snapshot convention across every organisation in a group.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Legal employerEntity and employment relationshipsWhose reporting position is assessed
Applicable routeRelevant private or public-authority provisionsWhich requirements govern the output
Snapshot populationEmployees at the relevant dateWhether the reporting test is met
Group arrangementsSeparate employer and shared-service responsibilitiesWho prepares and approves each report
Read the detailed guidance and evidence

Under the private/voluntary regulations, the relevant-employer definition uses 250 or more employees on the 5 April snapshot, with specified public bodies excluded from that instrument Regulation 1.

The government’s who-needs-to-report guidance is a useful operational starting point without replacing the route-specific regulations Official applicability guidance.

How should the reporting year and pay period be controlled?

Keep the snapshot, relevant pay period and publication timetable distinguishable rather than reuse an annual payroll total without checking the rules Regulations 1–7 When-to-report guidance.

Keep the periods explicitRequirements and evidence

Module 01 / 04

Snapshot

Record the relevant date for the employer’s route.

Read the detailed guidance and evidence

A payroll team may work with a tax year or management-reporting year that is not itself the complete basis for the statutory calculation.

The official data guidance separates the relevant employee populations and pay information needed, which makes the selection process as important as the arithmetic Preparing your data.

The review should preserve the actual extraction rules instead of leaving the next preparer to infer them from a file name.

Which outputs should the calculation file distinguish?

The statutory metrics cover hourly pay, bonus pay and employee distribution rather than one overall percentage.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Hourly gapsMean and median hourly-pay calculationsWhether both relevant measures were prepared
Bonus gapsMean and median bonus-pay calculationsWhether the bonus basis was assessed separately
Bonus participationRelevant proportions receiving bonus payWhether participation and bonus size are distinguished
Pay quartilesThe prescribed distribution calculationWhether the population was ranked and grouped on the correct basis
Read the detailed guidance and evidence

Regulation 2 specifies the six categories of information, while the calculation provisions and official guide define how the relevant outputs are produced Regulations 2–13 Making your calculations.

These plain-English groupings are a navigation aid rather than a substitute for the official definitions.

What could a fictional employer get wrong before calculating?

Fictional case: Netherton Logistics receives an HR headcount extract and a payroll extract that contain different sets of people at the snapshot.

Reconcile the peopleRequirements and evidence

Module 01 / 04

HR list

Identify the employment population represented.

Read the detailed guidance and evidence

The payroll team initially drops unmatched records to make the two files balance, which produces a clean spreadsheet without establishing the correct statutory population.

A better review reconciles the differences and records the reason each employee is included in the relevant calculation rather than rely on a convenient shared list.

The government data guide distinguishes relevant employees and full-pay relevant employees, so one blanket inclusion flag may not answer every calculation question Employee population guidance.

Which Netherton differences need investigation?

This original fictional case focuses on source reconciliation rather than invented pay figures or a universal exclusion rule.

Original fictional data-reconciliation case, not a prescribed employee-classification decision tree.
Evidence questionRecord to inspectDecision supported
HR-only recordEmployment and pay-period evidenceWhy the person appears in one extract
Payroll-only recordPayment reason and employment statusWhether the payment belongs to the relevant population
Different hours fieldContract and working-hours sourceWhich input the applicable calculation requires
Manual exclusionRecorded reason and reviewer decisionWhether convenience replaced a supported classification
Read the detailed guidance and evidence

The reviewer should not assume that every difference is an error or that the payroll system’s default inclusion rule matches the statutory definition.

Retain enough evidence for a successor to understand a classification without storing unnecessary personal data in every reporting workbook.

What should a reviewer inspect behind the final percentages?

Review the selected inputs and transformations before trusting a plausible-looking result Official calculation guide.

Trace the calculationRequirements and evidence

Module 01 / 04

Population

Identify the people entering the particular metric.

Read the detailed guidance and evidence

Netherton’s reviewer finds that a corrected hours record changed one metric but not the separate bonus calculation, which is not automatically inconsistent because the metrics have different inputs.

The useful check is whether the correct logic and population were applied to each result rather than whether every number moved in the same direction.

A software RFP should test a corrected employee record and show which outputs changed and why.

Which calculation controls are worth retaining?

Use checks that can expose a real population or transformation problem rather than merely repeat the final formula.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Input reconciliationHR/payroll differences and resolutionWhether the chosen population is supportable
Component mappingPay and bonus inputs with classificationsWhether the calculation uses the intended values
Change comparisonEarlier and corrected resultsWhether a revision affected the expected outputs
Independent reviewReproduction of selected calculationsWhether the logic is understandable outside the preparer’s file
Read the detailed guidance and evidence

The calculations guide should remain the reference for the actual method rather than a platform’s proprietary interpretation of a “standard pay gap”.

These editorial controls support preparation without establishing that every employee classification or legal question has been resolved.

What needs checking after the figures are ready?

The private-route regulations require a written accuracy statement and publication arrangements beyond generating the numbers Regulations 14–15.

Publish the accepted outputRequirements and evidence

Module 01 / 04

Statement

Identify the required confirmation and signatory.

Read the detailed guidance and evidence

The government service is the publication route for submitted figures, while EHRC’s publication guidance explains the separate website and statement steps Gender pay gap service EHRC publication guidance.

Netherton retains the accepted calculation and signed statement together rather than treat a successful portal upload as proof that the source data was correct.

The exact arrangements should follow the employer’s route rather than a universal signature instruction applied to every public authority.

What belongs in the release checklist?

Compare the data, statement and publication destinations before treating the reporting task as complete.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Employer identityName and reporting yearWhether the output belongs to the correct employer
Accepted figuresReviewed calculation versionWhether copied values match the approved file
Accuracy statementApplicable signature and approval recordWhether the required confirmation exists
Publication locationsWebsite and service recordsWhether the required information is accessible
Read the detailed guidance and evidence

EHRC describes enforcement against relevant employers that do not comply, so a missing publication step is not merely an internal administration issue EHRC enforcement guidance.

This guide does not infer a monetary penalty, compliance certificate or universal enforcement timetable from the existence of that guidance.

How should the narrative and action work use the results?

Separate the measured outcomes from the explanation and proposed response, with each claim supported by the evidence actually available Official action-plan guidance.

Explain without overclaimingRequirements and evidence

Module 01 / 04

Result

State what the published metric measures.

Read the detailed guidance and evidence

Netherton should not describe a lower gap as proof that a training programme caused the change without investigating workforce composition and other relevant evidence.

An action-plan publication and a statutory figure are related outputs rather than interchangeable evidence that all workplace fairness questions have been settled.

The ESG requirements guide helps keep this employer-specific output alongside the company’s other reporting routes.

What would an original working register preserve?

Plan a controlled inclusion-and-correction log rather than an uncontrolled copy of identifiable payroll information.

Original editorial preparation record, not a prescribed government form.
Evidence questionRecord to inspectDecision supported
Record referenceControlled employee identifier and sourceWhich source item the decision concerns
ClassificationMetric-specific inclusion and reasonWhy the record enters the calculation
CorrectionEarlier value, new value and affected outputsWhat changed during preparation
ReviewDecision owner and accepted versionWhich file supports publication
Read the detailed guidance and evidence

The register should reference protected source systems where possible and avoid circulating sensitive pay details through general sustainability-reporting folders.

A consultancy brief can specify population reconciliation, calculation review and publication support as separate deliverables.

What if a source error is found after approval?

Assess the affected calculation and publication version rather than silently overwrite the evidence file.

Trace the correctionRequirements and evidence

Module 01 / 04

Error

Identify the source problem and metrics affected.

Read the detailed guidance and evidence

Netherton receives a corrected payroll record after its statement was signed, so it needs to understand the effect before deciding what its published account should say.

The reviewer retains both calculations and the reason for revision instead of leaving the portal value and website report to drift apart.

The official publication and reporting guidance should inform the correction process for the relevant employer route EHRC publication guide Reporting guidance.

How can the team prepare a reviewable evidence file?

This editorial workflow organises preparation without certifying compliance or replacing a statutory process.

  1. 101

    Confirm the employer

    Identify entity, route and applicable snapshot.
  2. 202

    Freeze the extracts

    Record source systems and extraction rules.
  3. 303

    Reconcile the population

    Investigate HR/payroll differences.
  4. 404

    Classify the inputs

    Apply the relevant employee and pay definitions.
  5. 505

    Calculate each metric

    Keep the prescribed outputs distinguishable.
  6. 606

    Review corrections

    Reproduce logic and investigate unusual movements.
  7. 707

    Approve the output

    Retain the required accuracy confirmation.
  8. 808

    Publish consistently

    Match website and government-service information.
  9. 909

    Retain the evidence

    Preserve calculation, decisions and correction history.

Frequently asked

Questions people ask

Does every organisation with 250 staff use the same route?

No, assess the relevant employer and the applicable private or public-authority regulations.

Is 5 April the snapshot for every employer?

It is the snapshot in the private/voluntary regulations, while the public-authority route must be checked separately.

Is one overall percentage enough?

No, the regulations specify separate hourly, bonus, participation and quartile information.

Can the payroll default list be accepted without review?

Reconcile it to the relevant definitions and population, including the separate employee groups used in the calculations.

Is uploading to the service the whole publication task?

Check the applicable statement and own-website requirements as well as the service submission.

Does an improved gap prove an action worked?

Investigate the explanation and evidence rather than infer causation from a changed headline figure.

Sources

Primary sources

Primary provisions and official owner guidance checked on 26 October 2026; historical and draft resources are labelled in the guide.

Checked against 10 sources fromUK legislationGovernment Equalities OfficeUK GovernmentEHRC
  1. UK legislation
    Gender Pay Gap Information Regulations 2017
  2. UK legislation
    Specific Duties and Public Authorities Regulations 2017
  3. Government Equalities Office
    Who needs to report
  4. Government Equalities Office
    When to report
  5. Government Equalities Office
    Preparing your data
  6. Government Equalities Office
    Making your calculations
  7. Government Equalities Office
    Creating an action plan: overview
  8. UK Government
    Gender pay gap reporting service
  9. EHRC
    Publish your gender pay gap report
  10. EHRC
    Gender pay gap enforcement action
Book a free consultation