In February this year the UK Government announced that gender pay gap reporting for large firms would become law in October. The statement came after two sets of consultations carried out in 2015 and means that companies in the voluntary and private sector which employ more than 250 members of staff will be required to publicly disclose how much they pay their male and female staff.
Employers will also have to disclose how many men and women are in each pay range. Companies that fail to address pay disparities will be named and shamed in a new league table in a bid to speed up progress.
The date set for publication of the reports is 30th of April 2018 and will be a snapshot taken on the 30th of April 2017. The information must be freely accessible to the public on the company’s website, in addition to being entered into the Government reporting portal. So, with less than three months to go before the new rules come into effect, what can employers do now to ensure that they are ready to publish their pay data correctly?
Check whether the rules will apply to you
Even if a company employs less than 250 people at the present time, employers will need to consider whether that might change by 2017. Any organisation operating in the private or voluntary sectors which has close to 250 staff members would be advised to prepare for the new rules if there is a possibility that headcount might increase in the next 6 to 12 months.
Start gathering bonus pay data now
In addition to basic salary information, any bonus payments made to employees are also to be included in the data and will have to highlight the difference in mean bonus pay in the 12 months preceding the reporting date. What this means in reality is that firms which pay financial bonuses to staff may need to start collating figures from as early as May 2016.
Analyse past and current figures
Beyond merely gathering the information that will be legally required in 2018, employers may benefit from looking at their past record in order to try to predict whether a large gender pay gap has existed in the past and whether the trend is likely to continue into the report period. The benefit of looking into historical data is twofold: firstly, employers will be able to ascertain that they are, in fact, capturing the data required to adhere to the new rules; and, secondly, if a pay gap is uncovered, companies will have time to start to put measures and resources in place to rectify the situation.
Work on the narrative
Although not required, the Government has stated in response to the consultation that additional narrative giving context to any pay gaps is to be encouraged. This means that employers who expect to have a pay gap should start now to set out plans that will reduce the discrepancy. As the figures will be available for anyone to view, being able to provide additional information regarding gender pay gaps could be vital to protecting the company’s reputation with the public, staff and shareholders.
Review the final legislation
In October, when the final regulations are published, there may be changes to the draft regulations. More companies may fall into the scope of the regulations and there may be changes to the figures required. Employers should ensure that they are conversant with the regulations in order to meet the requirements correctly.