Gender pay gap reporting: getting it right

The government’s new gender pay reporting regulations have been well publicised and are an issue the property industry is well aware of, considering the well-known disparity of pay between the sexes.

But what do you do when your company has crunched the numbers and you know what your gender pay gap is? How should you display the information?

Should you provide an explanation or should you delay publishing until next April, when it becomes a legal requirement?

Here are some practical tips.

What information must be provided?

Your company’s gender pay report must set out the following calculations:

  1. The mean and median gender pay gap;
  2. The mean and median bonus gender pay gap;
  3. The proportion of males and females that are receiving bonuses; and
  4. The proportion of males and females in each quartile band.

There is no legal obligation to provide any other information, so the raw data itself does not have to be disclosed.

Where does the information have to be published?

You must publish your findings on your own UK website, in English, in a manner that is accessible to all employees and the public. Once published, the information must remain there for at least three years. You do not have to provide this information in a prominent place on your home page, but it should not be ‘buried’ either.

If your business does not have its own website because it is part of a group organisation, you can publish on the group’s UK website. If your business is not part of a larger corporate structure and does not have its own website, you should create a separate web page for your gender pay gap information.

You also have to upload the information to a government website at The government has said that it intends to create a publicly available league table or database.

Should you provide a narrative or just stick to the figures?

There is no need to do anything other than provide the required data. However, it is worth considering including a short narrative on your own website to provide context and set out the steps your organisation is taking to narrow the gap, or at least to explain why there is a gap. The starting point is to consider how your figures compare with the national average and, separately, those in your industry, if that information is available.

If your figures compare favourably with the national average, you might want to flag this to demonstrate that your business is already ahead of the curve. If they are higher than the national average, you may want to explain the reason for this, particularly if it is only in one part of the business, to avoid creating the impression that you have a significant gap throughout your organisation. Remember that your figures and what you say about them will act as a baseline for future years and can be used to show improvements.

Many of my company’s clients have decided against only providing the required data and are opting for more transparency. Being open about the issue, why it has arisen and sharing future plans will provide a positive message, even if the data itself could be viewed as disappointing.

Some of our clients have also opted to provide a short explanation of the differences between the gender pay gap and equal pay in an attempt to reduce the likelihood that staff will look at their figures and assume they have actionable claims.

How can you improve your figures?

The UK pay gap has started to fall (from 19.2% to 18.1% in the past year - the biggest drop for a decade). The real challenge for companies is to address the root causes of gender pay and other workplace inequalities and it is sensible to take time to analyse the data to try to understand what it is telling you about pay, recruitment, retention and progression within your organisation.

Should you delay publishing your data?

The deadlines for providing data from the first ‘snapshot date’ are 4 April 2018 for private companies and 30 March 2018 for public organisations. While you can leave publication until the last minute, we do not recommend that you do so. In fact, once you have crunched the numbers and properly considered the causes and agreed a strategy to address these, we think you should go ahead and publish. At the very least, this shows you are on top of the issue and are prepared to move forward to find solutions.

Melanie Stancliffe is an employment partner at Irwin Mitchell

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