The UK Government and the conciliation service, ACAS, have together produced draft guidance on how to comply with the new gender pay gap reporting regulations from April 2018.

The new regulations come into effect on 6 April 2017, and require employers with at least 250 employees to publish certain gender pay gap information on their websites by 4 April 2018. The new obligations will require the reporting of the difference between male and female average hourly pay, bonuses and weekly working hours, as at a snapshot date (broadly, being the payroll cycle in which 5 April falls). The first such snapshot date is 5 April 2017, and therefore, even though the reporting obligation is over a year away, the data on which to base that reporting is coming very soon.

The guidance explains what the gender pay gap is and how it may be perpetuated; industry sectors such as finance, energy and construction are identified as having greater discrepancies in gender pay.

The mandatory reporting is broken down into four stages by the guidance. Employers must: 1) extract the “essential information” (i.e., pay, bonuses and weekly working hours); 2) calculate the relevant averages (mean and median); 3) make a supporting statement (confirming the information’s accuracy, and also include an explanatory narrative); and 4) publish the results and statement on the employer’s own website and on a (still to be designated) government website.

A fifth step, but not legally required, is also given: implement plans to manage gender pay.

The draft guidance is available in full here.

What Should Employers Do Next?

Employers with or who are close to having 250 or more employees should consider the impact of these regulations and how they will report on the required information, as well as whether the 5 April snapshot date will provide an inaccurate impression of any gender pay gap in its workforce.