It has been over six months since the first 'snapshot' date of April 5 2017 and is less than seven months before the final deadline for employers with 250 or more UK employees to publish their first gender pay gap reports without incurring the wrath of the Equality and Human Rights Commission. This seems as good a time as any to ask where are we now?

There was little rush by employers to gain first mover advantage and publish their reports as soon as possible after the end of the April payroll run in order to demonstrate virtue or better performance than sectoral comparators.

Instead, only 80 of the estimated 7,000 employers with 250-plus employees (ie, little more than 1%) have uploaded their reports to the government's website. Nor has there been negative publicity for organisations publishing poor figures, although gender pay and the more litigious equal pay feature increasingly in the headlines.


The 80 submitted reports reveal the following snapshot:

  • The mean, mean pay gap is 12.09% and the mean, median pay gap is 11.64%. These numbers are low compared to the most recent Office for National Statistics study of the nationwide gender pay gap (18.1% in 2016). This is likely due to the fact that a high number of the 80 employers are public sector organisations, which usually have lower pay gaps than their private sector counterparts.
  • In a similar vein, the mean, mean bonus gap is 10.5% and the mean, median bonus gap is 12.23%. However, the picture is distorted by the fact that 29 of the 80 organisations reported a 0% mean bonus gap and a 0% median gap (ie, they pay no bonuses). If these organisations are removed, gaps of 30%, 40% or even 50% are commonplace.
  • On average, 29.95% of men and 28.85% of women received a bonus – again distorted by the many organisations paying no bonuses.
  • Unsurprisingly, the quartiles data shows a steady progression from a preponderance of female employees in the lowest paid quartiles to a preponderance of male employees in the highest paid quartiles. Across the 80 organisations, on average, women comprise:
    • 54.91% of the lowest paid quartile;
    • 50.52% of the lower to mid-paid quartile;
    • 45.14% of the upper to mid-paid quartile; and
    • 38.64% of the upper paid quartile.
  • Eleven organisations reported a 0% median pay gap. This seems surprising; however, in any workforce with a large group or majority of employees in the middle earning the same (in many cases, the national minimum wage) this would be the inevitable result. So far, only two organisations (including the British Museum) have achieved the nirvana of a 0% mean gap.
  • Most organisations have elected to publish a narrative to sit alongside their headline statistics. This is a mixture of context (eg, why the stats are as they are or why they are not as bad as they look) and an account of the efforts and initiatives underway to try to tackle the larger gaps.
  • Finally, Hall Cleaning Services Ltd reported the narrowest mean (0.1%) and median (0.0%) pay gaps to date. Conversely, Octopus Capital Ltd reported the largest mean pay gap (38.1%) and the Office for Nuclear Regulation reported the largest median gap (55.3%).

However, as previously highlighted, the gender pay gap reporting figures may not be reliable statistics.

For further information on this topic please contact Colin Leckey at Lewis Silkin by telephone (+44 20 7074 8000​) or email ([email protected]). The Lewis Silkin website can be accessed at