q Gender Pay Gap Reporting – The Deadline is Soon! - Thrive Law

Gender Pay Gap Reporting – The Deadline is Soon!

Employment Law, For Employers, Human Resources, Law Updates

Are you a private company? On 5 April 2022, did you have more than 250 employees?

If so, you must report your gender pay gap information by 4 April 2023.

Reporting Obligations

Any private employer with more than 250 employees on a snapshot date (5 April) must publish their gender pay gap information for that date, by the following April.

As an example, if X Ltd had a headcount of 400 employees on 5 April 2022, they must report their 2022-2023 data by 4 April 2023.

The employer must base their reports on the payroll information on the snapshot date. They must submit their data on the Government’s gender pay gap service, and publish the data and a written statement on their website.

The reporting process and requirements are very specific, and we therefore advise that, if you fall within the requirements, you review the Government guidance on gender pay gap reporting and, if necessary, seek legal advice on your obligations.

It’s really important you act promptly and precisely. If you don’t report on time or report inaccurate data, this may result in court orders and fines, not to mention the reputational risk as you will get a “late badge” which is visible to the public and is used to indicate your failure to report.


Why is there an obligation to report the gender pay gap? In short, the gender pay gap is intended to measure the difference between men and women’s average earnings in the organisation. It’s a straightforward average, so it would demonstrate if (for example) you have more women in lower paid roles, as this would bring the average down.

It’s different to equal pay, which is the principle of equal pay for performing equal work of equal value.

To summarise, an employee can bring an Equal Pay claim if they can demonstrate that they are doing the same work as an equivalent from the other sex, but being paid less. The gender pay gap report might show if an employer has a more systemic issue with men being, on average, in higher paid roles.

The point of the reporting obligations are to try to highlight, narrow, and eventually eliminate the pay differences between men and women. Since reporting obligations began in 2017, the gender pay gap between full-time employees has fallen from 9.1 percent in 2017 to 7.9 percent in 2021.

Future Obligations

The impact of the Gender Pay Gap Regulations were meant to be evaluated by the Government every five years; the results were due to be published by the end of March 2022. They have not been published to date. When this evaluation is eventually published, we may see changes to some of the reporting obligations.

There have also been calls to expand reporting obligations to consider ethnicity and disability. The Government considered ethnicity reporting in 2018, but decided in 2022 that there were “significant obstacles” in an ethnicity pay gap reporting mechanisms and that it did not want to impose additional burdens on employers “as they recover from the pandemic”.

In relation to disability reporting, there have been calls for similar obligations as gender pay gap reporting, but some suggest that this should not be mandatory. The argument is that mandatory reporting does not guarantee that the disability employment gap will lessen and that such reporting would only capture a snippet of the full picture as only large organisations would be required to report. Moreover, it would only measure the number of disabled people who are currently employed rather than the number who may have lost employment or be looking for work.

How can Thrive help?

We can help you understand your gender pay gap reporting obligations and advise you on this process, ensuring you comply and report accurately. Contact us.


Please note this blog is for reference purposes only and is only accurate at which the date it was published. It does not constitute legal advice and should not be relied upon as such. Specific Legal advice about your specific circumstances should always be sought separately before taking or deciding not to take any actions. Please contact us if you have any questions on enquiries@thrivelaw.co.uk.

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