The median gender pay gap among full-time employees in the UK stood at 6.8% in April 2026, and at 12.3% across all employees, according to the Office for National Statistics [1]. Every employer in Great Britain with 250 or more employees on its snapshot date must calculate and publish six figures that show its own gap, within a year of that date [2].
Gender pay gap reporting is often treated as an HR or communications exercise. In practice, almost every input comes from payroll: basic pay, allowances, shift premiums, bonuses, salary sacrifice, leave status and contracted hours, all for one specific pay period. An error in how the payroll data is extracted produces a wrong published figure, and the published figure stays online for at least three years [8].
The regime is also changing. The Employment Rights Act 2025 inserted a new power into the Equality Act 2010 that allows the government to require large employers to publish equality action plans, covering the gender pay gap and menopause support [10]. Action plans are voluntary for the 2026 to 2027 reporting year and, subject to legislation, become mandatory from spring 2027 [11].
This guide sets out who must report, the snapshot dates and deadlines, how payroll data turns into hourly pay, the six calculations, the publication and enforcement rules, and how action plans and the planned ethnicity and disability pay gap reporting will extend the same payroll workload.
Key takeaways
- Employers with 250 or more employees on the snapshot date must report six gender pay gap figures and publish them within a year [2].
- The snapshot date is 5 April for private and voluntary sector employers and 31 March for most public authorities, with deadlines of 4 April and 30 March the following year [3].
- Hourly pay is built from the pay period containing the snapshot date, after salary sacrifice and excluding overtime, redundancy pay and benefits in kind [4].
- Employees paid less than usual because of leave, such as statutory maternity pay or sick pay, are excluded from the hourly pay figures but stay in the bonus figures [4].
- The Equality and Human Rights Commission can investigate late or missing reports, and ignoring a resulting court order can lead to an unlimited fine [14].
- Action plans with at least one gender pay gap action and one menopause action are voluntary now and expected to become mandatory from spring 2027 [11].
What gender pay gap reporting measures
The gender pay gap is the difference between the average pay of men and women across an organisation [6]. It is a comparison of averages over the whole workforce, not a comparison of two people doing the same job.
Gender pay gap versus equal pay
Equal pay is a separate legal duty under the Equality Act 2010: men and women must receive the same pay for equal work [6]. An organisation can comply fully with equal pay law and still report a large gender pay gap, for example where more men than women hold senior, higher-paid roles [17].
The distinction matters to payroll teams because the reporting exercise does not test whether any individual is underpaid. It measures the shape of the pay distribution. A wide gap is a signal to investigate, and the published supporting narrative is where an employer explains the causes it has found [6].
The legal basis
Section 78 of the Equality Act 2010 gives ministers the power to require employers with at least 250 employees to publish information about differences in pay between male and female employees [9]. The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 use that power for private and voluntary sector employers, setting 5 April as the snapshot date and listing the six required figures in regulations 8 to 13 [8].
Most public authorities in England report under separate specific duties regulations, which use a 31 March snapshot date [22]. Public authorities in Scotland and Wales follow different rules again, set out in separate guidance [19].
Who must report
The duty applies to any employer with 250 or more employees on its snapshot date [2]. Employers below the threshold can report voluntarily, and the gender pay gap service publishes both mandatory and voluntary reports [18].
Counting the 250
The count is a headcount of individuals, not full-time equivalents, so each part-time worker and each job-sharer counts as one employee [2]. Apprentices, seasonal, temporary, casual and zero-hours workers count if they are employees on the snapshot date, however long they have worked there [2].
The table below summarises how the most common worker types are treated in the headcount, according to the official guidance [2].
| Worker type | Counts towards the 250? | Included in the pay calculations? |
|---|---|---|
| Part-time and job-share employees | Yes, one each | Yes |
| Employees on leave | Yes | Hourly pay only if on full pay; bonus figures always |
| Agency workers | No, they count for the agency | No |
| Partners and LLP members | No | No |
| Salaried partners treated as employees for payroll | Yes | No |
| Self-employed people who must do the work personally | Yes | Yes |
Group companies and multiple payrolls
Each legal entity in a group that meets the 250 threshold must calculate, report and publish its own figures, and a group can add combined figures and a narrative on top [2]. An entity that runs more than one payroll must merge the data and report a single set of figures [19].
For multi-entity employers, this is where payroll architecture matters. Each PAYE scheme and each legal entity needs its employee data tagged cleanly so that the reporting extract follows the legal employer, not the payroll run. Moonworkers' enterprise payroll setup keeps employers, schemes and pay runs as separate records for exactly this kind of entity-level reporting.
Employees outside Great Britain
Employers based in Great Britain may need to include employees working abroad, and employers based elsewhere may need to include employees working wholly or partly in Great Britain, including Northern Ireland employers with 250 or more employees working in Great Britain [2]. The general test is whether the employee could bring an Equality Act 2010 claim in an employment tribunal, with indicators such as a contract under British law and UK tax applying [19].
Snapshot dates and deadlines
The reporting cycle runs from a fixed snapshot date to a deadline one day short of a year later [3]. The table below sets out the two cycles.
| Employer type | Snapshot date | Reporting deadline (following year) |
|---|---|---|
| Most public authorities | 31 March | 30 March |
| Private, voluntary and other public authority employers | 5 April | 4 April |
The Equality and Human Rights Commission treats 23:59 on the deadline date as the cut-off [14]. Figures can be submitted at any point before then, and the service allows calculations to be entered, edited and saved before final submission [7].
For a private sector employer, the 5 April snapshot date falls on the last day of the tax year. The pay period that contains it is usually the final weekly or monthly run of the year, the same run that feeds the year-end Full Payment Submission. Payroll teams can therefore archive a frozen copy of that run as soon as it is finalised, rather than reconstructing it months later from amended records.
How payroll data becomes hourly pay
The hourly pay figures use only full-pay relevant employees and only the pay period that contains the snapshot date [4]. This is the step where most reporting errors start, because it depends on payroll classifying each pay element correctly.
Full-pay relevant employees
A full-pay relevant employee is someone employed on the snapshot date who received their usual full basic pay in the pay period, or who was paid less than usual for a reason other than leave [4]. Anyone paid less than usual because of annual, sick, maternity, paternity, adoption, parental, shared parental, special, study or sabbatical leave is excluded from the hourly pay figures [4].
An employee on statutory maternity pay in the snapshot period is therefore excluded from the quartiles and the hourly pay gaps, but still counts in the bonus figures [2]. An employee on strike who earned less than usual still counts as full-pay relevant, because the reduction was not caused by leave [4].
What counts as ordinary pay
Ordinary pay is measured after any salary sacrifice reduction but before income tax, National Insurance and pension deductions [4]. Regulation 3 of the 2017 Regulations defines it as basic pay, allowances, piecework pay, pay for leave and shift premium pay [8]. The table below separates the elements a payroll extract must keep from those it must drop [4].
| Included in ordinary pay | Excluded from ordinary pay |
|---|---|
| Basic pay and pay for paid leave | Overtime pay and allowances earned in overtime |
| Allowances for core duties (first aider, on-call, location, vehicle) | Redundancy and termination pay |
| Piecework pay | Pay in lieu of untaken annual leave |
| Shift premiums | Reimbursed business expenses |
| Pay after salary sacrifice | Benefits in kind and interest-free loans |
The salary sacrifice rule has a direct payroll consequence. A salary sacrifice arrangement for pensions, cycles or cars lowers the reported ordinary pay of every employee who joins it, so a scheme with uneven take-up between men and women can move the published gap [4]. Only amounts actually paid in the snapshot period count: back pay relating to other periods is left out [4].
Overtime is excluded entirely, both from pay and from hours, which is why payroll codes need to separate overtime from basic pay rather than folding everything into one gross figure [4].
Bonus pay
Bonus pay covers money, vouchers and securities linked to profit sharing, productivity, performance, incentive or commission [8]. The guidance adds long service awards with a monetary value, and treats one-off recruitment or retention incentives as bonus pay rather than ordinary pay [4].
Shares and options count only when they triggered an income tax charge in the 12 months ending on the snapshot date [4]. Bonus pay is used twice: a prorated share of any bonus paid in the snapshot period feeds the hourly pay figure, and the full amount paid in the 12 months to the snapshot date feeds the three bonus figures [4].
Weekly hours
Weekly working hours exclude all overtime, paid or unpaid [4]. For employees with regular hours, the figure is the contracted hours in the employment contract, even if extra unpaid hours are often worked [4].
For employees whose hours vary, the hours are averaged over the 12 weeks ending with the last full week of the snapshot pay period, swapping any week without work for an earlier working week [4]. Regulation 7 of the 2017 Regulations sets out the same weekly hours rules in law [8].
The hourly pay formula
The calculation takes ordinary pay plus any prorated bonus for the period, multiplies it by 7 divided by the number of days in the pay period, and divides the result by weekly working hours [4]. Monthly pay periods use 30.44 days, so the monthly multiplier is 7 divided by 30.44 [4].
The guidance gives a worked case for a 14-day pay period: £1,000 of ordinary pay plus £300 of bonus gives £1,300, which halves to £650 for one week and divides by 40 hours to give hourly pay of £16.25 [4]. Applying the same formula to a monthly employee with £2,800 of ordinary pay and 37.5 contracted hours gives £643.89 for one week and hourly pay of £17.17, using the 30.44-day month set out in the guidance [4].
The six calculations
The 2017 Regulations require six figures [27], and the guidance sets out how each is calculated [5]. The table below lists them with the population each one uses.
| Figure | What it measures | Population |
|---|---|---|
| Pay quarters | Share of men and women in each hourly pay quarter | Full-pay relevant employees |
| Mean hourly pay gap | Difference in mean hourly pay | Full-pay relevant employees |
| Median hourly pay gap | Difference in median hourly pay | Full-pay relevant employees |
| Bonus proportions | Share of men and of women receiving bonus pay | All relevant employees |
| Mean bonus gap | Difference in mean bonus pay | All relevant employees |
| Median bonus gap | Difference in median bonus pay | All relevant employees |
Mean and median gaps
Each gap uses the same formula: the men's figure minus the women's figure, divided by the men's figure and multiplied by 100 [5]. A positive result means women's pay or bonuses are lower, and a negative result means men's are lower; figures can be reported as whole percentages or to one decimal place [5].
A small illustration shows why the two averages tell different stories. Take five men with hourly pay of £14.20, £16.80, £18.50, £22.40 and £41.00, and five women with hourly pay of £13.10, £15.60, £17.90, £19.80 and £26.50. The mean for men is £22.58 against £18.58 for women, a mean gap of 17.7%, while the medians are £18.50 and £17.90, a median gap of 3.2%. The single high earner pulls the mean far more than the median, which is why the guidance requires both [5] and why the ONS headline figures use the median [1]. The same ONS figures are drawn from the Annual Survey of Hours and Earnings, which samples employee pay records directly [25].
Pay quarters
Employees are ranked from highest to lowest hourly pay and split into four equal groups: upper, upper middle, lower middle and lower [5]. Where the number is not divisible by four, leftover employees go first to the lower quarter, then to the upper middle and lower middle, and employees on identical pay are split so that the proportion of men and women stays the same across the quarters they span [5].
The quarters are often the most revealing figure. A workforce with a modest mean gap can still show 70% men in the upper quarter and 70% women in the lower quarter, which points to representation rather than pay rates as the driver. Regulation 13 makes the quarter split a legal requirement in its own right [8].
Bonus figures
The bonus period is the 12 months ending on the snapshot date [5]. The proportion figure divides the number of men, or women, who received any bonus by the total number of men, or women, and the mean bonus divides total bonus by the number of recipients only [5].
Bonuses are not prorated for part-time employees in these figures, so a workforce where women are more likely to work part-time and receive pro rata bonuses will usually show a wider bonus gap than hourly pay gap [4]. The supporting narrative is the place to explain that effect [6].
Recording sex in the data
The guidance was updated on 21 May 2026 after a Supreme Court ruling on the meaning of sex in the Equality Act 2010 [24]. It now states that "male", "female", "men" and "women" in the Act refer to biological sex, and that employees holding a Gender Recognition Certificate are reported by biological sex, not acquired gender [4].
The same guidance tells employers not to single out individual employees to ask about their sex or gender identity, and not to ask for documents to prove it [4]. It also warns that disclosing an employee's gender before a certificate was issued can be a criminal offence, so the field used for reporting needs restricted access in the payroll or HR system [4].
Publishing, signing off and enforcement
Once calculated, the six figures go to two places: the government's gender pay gap service and the employer's own website [6]. Both are public, and the service lets anyone search and compare employers by name or sector [18].
Website publication and the written statement
Regulation 15 requires the information to stay on the employer's website, accessible to employees and the public, for at least three years [8]. Private and voluntary sector employers must also upload a written statement confirming the figures are accurate, signed by an appropriate person such as a director, partner or senior officer [6].
The signatory's name and job title are published alongside the figures on the government service [8]. That personal sign-off is a reason for the person signing to ask for an audit trail back to the payroll run, not just a spreadsheet of totals. A payroll API that exposes pay elements, hours and leave status by employee and period makes that trail reproducible from source data.
How the EHRC enforces the duty
The Equality and Human Rights Commission sends warning notices first, then investigates, and where it finds a breach issues an unlawful act notice directing the employer to report [14]. Its investigation power comes from section 20 of the Equality Act 2006, and the unlawful act notice from section 21 [15].
If a notice is ignored, the Commission can seek a court order, and failing to comply with that order is an offence punishable by an unlimited fine [14]. The Commission names employers that miss the deadline: 28 in 2022, 8 in 2023, 6 in 2024 and 10 in 2025 [14]. Its earlier formal investigations ended with every investigated employer reporting [26].
The late badge
Employers that miss the deadline receive a "late badge" on their public record on the gender pay gap service [6]. An employer that reported before but has fallen below 250 employees should say so through the service, which prevents a late badge being applied in error [19].
Action plans under the Employment Rights Act 2025
Section 78A of the Equality Act 2010, inserted by the Employment Rights Act 2025 and in force from 6 April 2026, allows regulations to require employers with 250 or more employees to develop and publish equality action plans [10]. The enabling power sits in the Employment Rights Act 2025 itself, which received Royal Assent as chapter 36 of 2025 [23].
What a plan must contain
The government launched the plans on 4 March 2026 and encouraged large employers to publish from April [12]. A plan must include at least two actions from the government's recommended list: at least one to address the gender pay gap and at least one to support employees experiencing the menopause [11].
The recommended actions are published as a separate list for employers to choose from [13]. Each legal entity with 250 or more employees submits its own plan, and private and voluntary sector employers name a responsible person when they submit [11].
Timeline
The table below sets out the action plan timeline published in the guidance [11].
| Stage | Position |
|---|---|
| Voluntary publication | 2026 to 2027 reporting year |
| Deadline for most public authorities | 30 March 2027 |
| Deadline for private, voluntary and other employers | 4 April 2027 |
| Mandatory plans | From spring 2027, subject to legislation |
Acas expects the plans to become mandatory in 2027 for employers with 250 or more workers and offers support to employers preparing them [17]. Plans are published on the same gender pay gap service as the figures, so they sit next to the numbers they are meant to address [11].
Ethnicity and disability pay gaps come next
On 25 March 2026, the government committed to mandatory ethnicity and disability pay gap reporting for employers with 250 or more staff, built on the existing gender pay gap framework [20]. The consultation response, published the same day, includes indicative draft clauses covering six pay gap metrics and new workforce composition data [21].
For payroll, that means the same snapshot extract will need to serve three reports instead of one. Employers that build a clean, repeatable process for hourly pay now, with pay elements coded once and leave status recorded per period, will be able to reuse it when ethnicity and disability reporting starts. Accountants running payroll for several large clients can use a multi-client payroll dashboard to keep each client's snapshot data separate.
A practical checklist for payroll teams
The checklist below follows the order of the official guidance, from headcount to publication [24]:
- Confirm the headcount for each legal entity on the snapshot date, counting individuals rather than full-time equivalents.
- Freeze a copy of the pay run that contains the snapshot date for each entity.
- Flag employees on reduced pay because of leave, and remove them from the hourly pay population only.
- Map every pay code to ordinary pay, bonus pay or excluded pay, applying amounts after salary sacrifice.
- Record contracted weekly hours, or a 12-week average for variable-hours staff.
- Pull all bonus payments for the 12 months ending on the snapshot date.
- Calculate the six figures, check them against the prior year, and draft the narrative.
- Obtain the signed written statement, submit to the service and publish on the website.
Payroll data models that store pay elements as typed components, rather than as a single gross figure, make steps 4 and 6 a query rather than a manual exercise. The Moonworkers API documentation shows how pay components and leave periods are exposed per employee, and the UK payroll software built on the same engine is HMRC-recognised for Real Time Information submissions.
Conclusion
Gender pay gap reporting looks like an HR disclosure, but its accuracy is decided in payroll: which pay codes count as ordinary pay, which employees were on reduced pay because of leave, how salary sacrifice and bonuses are treated, and which hours are used. Each of those choices is set out in the guidance and the 2017 Regulations, and each leaves a trace in the published figures for at least three years.
The direction of travel is clear. Action plans move the regime from disclosure to commitment, and ethnicity and disability pay gap reporting will reuse the same snapshot data. Employers whose payroll can reproduce the snapshot extract on demand, entity by entity, will treat each new report as an extra query rather than a new project.
Frequently asked questions
Do employers with fewer than 250 employees have to report their gender pay gap?
No. The legal duty applies only to employers with 250 or more employees on the snapshot date, counted as a headcount of individuals rather than full-time equivalents [2]. Smaller employers can still report voluntarily through the gender pay gap service [18].
Are employees on maternity leave included in gender pay gap figures?
They count towards the 250 headcount and are included in the three bonus figures. If they were paid less than their usual full pay in the snapshot pay period because of the leave, for example while receiving statutory maternity pay, they are excluded from the hourly pay quarters and the mean and median hourly pay gaps [2] [4].
Is salary sacrifice included in gender pay gap ordinary pay?
Ordinary pay and bonus pay are both measured after any salary sacrifice reduction, so an employee in a salary sacrifice pension or car scheme reports the lower, post-sacrifice figure [4]. Pension contributions taken as ordinary deductions are not subtracted, because ordinary pay is measured before pension deductions, as regulation 3 of the 2017 Regulations frames ordinary pay before deductions [8].
What happens if an employer misses the gender pay gap reporting deadline?
The employer receives a public late badge on the gender pay gap service [6]. The Equality and Human Rights Commission can investigate, issue an unlawful act notice and seek a court order, and failing to comply with a court order is punishable by an unlimited fine [14].
