We have been told by the Government Equalities Office that they are still planning to lay the final regulations as soon as the parliamentary timetable allows. This could well be this month. We also understand that it's likely the Government's response to the consultation will either be issued before the final regulations are laid, or at the same time. This will help to provide clarity on the outstanding points that many of you are waiting to hear about before starting to analyse your data. In particular, the consultation response should clarify whether:
- family leave payments ought to be included in definition of pay?
- the draft bonus definition has been refined?
- bonus eligibility data will need to be disclosed?
- quartiles are created using pay range or number of employees?
- the wider definition of employees will be adopted (increasing those organisations in scope)?
- reporting is at single legal entity or group level?
In the meantime, ensuring you have a project team in place who are ready to start looking at the numbers, or re-run data, as soon as final pay and bonus definitions are known, is a step all commercial organisations would be wise to take now.