Over the weekend the Government gave a steer on its latest thinking on the forthcoming gender pay gap reporting obligations.

We are waiting for the Government’s formal response to its first consultation on how best to implement mandatory gender pay reporting. However, in the meantime, the Government has suggested:

  • bonuses will need to be included in gender pay gap calculations, not just basic pay. This is significant for employers in sectors such as financial services, where variable compensation forms a large element of total pay;
  • the new gender pay gap reporting obligation will include large employers in the public sector, not just the private and voluntary sectors.

A number of key questions remain unanswered, such as:

  • what level of detailed information should be required, for example a breakdown by full and part-time employees or by grade/job rather than just one overall figure for the whole workforce;
  • whether employers should be required or entitled to provide contextual information to explain their pay gap figures; and
  • where employers should be required to publish their gender pay information.

We expect a second consultation on the fine detail of the new regime soon, and in any event before the end of 2015.