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.
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Employer
Identify the organisation subject to the reporting assessment.
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Route
Determine which regulatory provisions apply.
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Snapshot
Identify the relevant population and date.
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Output
Identify the figures and publication steps required.
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.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Legal employer | Entity and employment relationships | Whose reporting position is assessed |
| Applicable route | Relevant private or public-authority provisions | Which requirements govern the output |
| Snapshot population | Employees at the relevant date | Whether the reporting test is met |
| Group arrangements | Separate employer and shared-service responsibilities | Who 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.
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Snapshot
Record the relevant date for the employer’s route.
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Pay period
Identify the period containing that date.
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Bonus period
Identify the applicable bonus evidence separately.
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Publication
Record the deadline and accepted reporting year.
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.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Hourly gaps | Mean and median hourly-pay calculations | Whether both relevant measures were prepared |
| Bonus gaps | Mean and median bonus-pay calculations | Whether the bonus basis was assessed separately |
| Bonus participation | Relevant proportions receiving bonus pay | Whether participation and bonus size are distinguished |
| Pay quartiles | The prescribed distribution calculation | Whether 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.
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HR list
Identify the employment population represented.
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Payroll list
Identify who was paid and why a record appears.
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Difference
Investigate joiners, leavers and other mismatches.
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Decision
Retain each inclusion decision and its basis.
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.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| HR-only record | Employment and pay-period evidence | Why the person appears in one extract |
| Payroll-only record | Payment reason and employment status | Whether the payment belongs to the relevant population |
| Different hours field | Contract and working-hours source | Which input the applicable calculation requires |
| Manual exclusion | Recorded reason and reviewer decision | Whether 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.
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Population
Identify the people entering the particular metric.
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Pay
Identify the pay components and relevant period.
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Hours
Identify the working-hours information used.
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Transformation
Retain calculation logic and any manual changes.
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.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Input reconciliation | HR/payroll differences and resolution | Whether the chosen population is supportable |
| Component mapping | Pay and bonus inputs with classifications | Whether the calculation uses the intended values |
| Change comparison | Earlier and corrected results | Whether a revision affected the expected outputs |
| Independent review | Reproduction of selected calculations | Whether 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.
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Statement
Identify the required confirmation and signatory.
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Website
Check the employer’s own publication arrangements.
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Service
Prepare the required government-service submission.
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Version
Match published figures to the reviewed calculation.
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.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Employer identity | Name and reporting year | Whether the output belongs to the correct employer |
| Accepted figures | Reviewed calculation version | Whether copied values match the approved file |
| Accuracy statement | Applicable signature and approval record | Whether the required confirmation exists |
| Publication locations | Website and service records | Whether 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.
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Result
State what the published metric measures.
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Analysis
Investigate factors supported by the employer’s evidence.
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Action
Identify the response and its intended effect.
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Review
Assess progress without assuming causation.
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.
| Evidence question | Record to inspect | Decision supported |
|---|---|---|
| Record reference | Controlled employee identifier and source | Which source item the decision concerns |
| Classification | Metric-specific inclusion and reason | Why the record enters the calculation |
| Correction | Earlier value, new value and affected outputs | What changed during preparation |
| Review | Decision owner and accepted version | Which 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.
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Error
Identify the source problem and metrics affected.
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Recalculation
Produce a reviewable comparison of results.
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Approval
Resolve the appropriate confirmation of revised figures.
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Publication
Align the records at the relevant destinations.
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.
- 101
Confirm the employer
Identify entity, route and applicable snapshot. - 202
Freeze the extracts
Record source systems and extraction rules. - 303
Reconcile the population
Investigate HR/payroll differences. - 404
Classify the inputs
Apply the relevant employee and pay definitions. - 505
Calculate each metric
Keep the prescribed outputs distinguishable. - 606
Review corrections
Reproduce logic and investigate unusual movements. - 707
Approve the output
Retain the required accuracy confirmation. - 808
Publish consistently
Match website and government-service information. - 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.
- UK legislationGender Pay Gap Information Regulations 2017
- UK legislationSpecific Duties and Public Authorities Regulations 2017
- Government Equalities OfficeWho needs to report
- Government Equalities OfficeWhen to report
- Government Equalities OfficePreparing your data
- Government Equalities OfficeMaking your calculations
- Government Equalities OfficeCreating an action plan: overview
- UK GovernmentGender pay gap reporting service
- EHRCPublish your gender pay gap report
- EHRCGender pay gap enforcement action
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