Gender Pay Gap Reporting 2025: Are You Ready?

Who must report

The duty to report applies to employers with 250 or more employees in England, Scotland, and Wales on the snapshot date — 5 April for private and voluntary sector organisations, 31 March for public sector employers. Northern Ireland has separate legislation and is not covered by the Great Britain regulations.

The reporting deadlines are equally split: public sector employers must publish by 30 March each year, while private and voluntary sector employers have until 4 April. Both must submit their data to the government's online reporting service and publish it on their own website.

Non-compliance is enforced by the EHRC. There is no automatic financial penalty for late or non-reporting, but the EHRC has powers to investigate and can pursue employers who fail to publish through formal enforcement action, including unlawful act notices. More significantly in practice, the EHRC publishes lists of non-compliant employers, which carries substantial reputational risk. Every year, a small number of organisations are named — and it is noticed.

The six required metrics

The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 require six specific calculations. These are not optional extras or best-practice additions — all six must be reported.

1. Mean gender pay gap in hourly pay. The difference between the mean hourly pay of male and female employees, expressed as a percentage of men's mean pay. The mean is calculated by adding up all the hourly rates and dividing by the number of employees. It is sensitive to outliers: a small number of very highly paid individuals at either end of the distribution can materially distort this figure.
2. Median gender pay gap in hourly pay. The difference between the median hourly pay of male and female employees, expressed as a percentage of men's median pay. The median is the middle value when all hourly rates are ranked in order. It is a better representation of the typical employee experience and less affected by the very highest earners.
3. Mean bonus pay gap. Calculated in the same way as the mean pay gap, but applied to bonus pay received in the 12 months ending 5 April.
4. Median bonus pay gap. The median equivalent, applied to bonus pay in the same period.
5. Proportion of men and women receiving a bonus payment. The percentage of each gender who received a bonus in the relevant 12-month period. This metric is often more revealing than the gap itself — a large difference in the proportion receiving a bonus at all can signal structural issues in how performance-related pay is allocated.
6. Proportion of men and women in each pay quartile. Your workforce is divided into four equal pay quartiles — lower, lower middle, upper middle, and upper. The proportion of men and women in each quartile must be reported. This is the metric that most directly illustrates occupational segregation and the underrepresentation of women in senior roles.

The calculation errors everyone makes

The regulations are more specific about what counts as pay than most employers initially assume. Getting the inputs wrong means getting every metric wrong.

Ordinary pay includes basic pay, paid leave, maternity or other statutory pay, sick pay, area or other allowances, piecework pay, and shift premium pay. It explicitly excludes overtime pay. This is one of the most common errors — overtime is frequently included by mistake, which distorts the pay gap figure, particularly in sectors where overtime patterns differ significantly by gender.

Bonus pay includes profit-sharing, productivity, performance, incentive, and commission pay. It is reported separately and for a different period (the 12 months ending 5 April, rather than the snapshot week).

Other common mistakes include using monthly rather than weekly pay figures without making the correct adjustment, miscounting who is included in the workforce (employees only, not workers or self-employed contractors), and misidentifying the snapshot week. The snapshot date is 5 April — you look at the pay period containing that date.

The narrative report: why it matters more than you might think

The narrative accompanying your data is optional in strict legal terms. It is not optional in any meaningful sense for an organisation that wants to be taken seriously.

A gender pay gap figure without context is almost meaningless. A 15% median gap in a technology company might reflect a severe and entrenched underrepresentation of women in senior engineering roles — or it might reflect a workforce that is genuinely more balanced than it appears once you account for the specific occupational distribution. The numbers cannot tell that story. Only the narrative can.

Practically, your narrative will be read by: current employees, who will draw conclusions about whether the organisation is honest and committed; prospective employees, who increasingly scrutinise GPG reports before accepting offers; journalists, who routinely compare reports across sectors and name organisations with large gaps or weak narratives; and investors and clients, particularly in regulated industries where ESG credentials are assessed.

A good narrative sets out the genuine causes of any gap clearly and without defensiveness. Common explanations — occupational segregation, the higher proportion of women in part-time roles, underrepresentation at the most senior levels — are legitimate and recognised. What is not credible is a narrative that states a gap exists while declining to explain why, or that attributes the gap to factors outside the organisation's control without also setting out what the organisation is doing to address those factors.

What good action plans actually include

The best action plans are specific, time-bound, and honest about where the organisation currently is. They distinguish between actions already taken, actions underway, and commitments for the coming year. They are not a list of things the organisation already does well.

• Specific targets for women in leadership. "We aim to increase the proportion of women at director level from 28% to 35% by 2027" is an action plan. "We are committed to increasing female representation in senior roles" is not.
• Flexible working provisions that are genuinely accessible to all levels of the organisation, not just roles where flexibility is easy to accommodate.
• Pay review processes that explicitly check for gender-related bias in how pay decisions are made, including starting salaries, performance pay, and promotion-linked increases.
• Returner programmes that support people — predominantly women — returning from career breaks, with structured re-entry and accelerated development where appropriate.
• Targeted sponsorship and mentoring for women at the levels immediately below the most senior, where the pipeline typically thins.

Vague commitments are noticed and criticised, including by the EHRC in its annual analysis of reporting trends. They also tend to produce no measurable change, which means the following year's report looks identical or worse.

If your gap has widened

Do not ignore it, and do not try to explain it away. A gap that has widened between years is not automatically a sign of regression — workforce restructuring, sector changes, the departure of senior women, or a change in how bonus pay has been allocated can all affect the figures legitimately. But none of those explanations remove the need for transparency.

An employer who publishes a widened gap with a clear, credible explanation of why it happened and what they are doing about it is in a significantly stronger position — reputationally, legally, and in terms of employee trust — than an employer who publishes the same gap with no comment. The temptation to let the numbers speak for themselves should be resisted. They don't speak; they leave space for others to fill.