Gender Pay Gap Reporting: latest developments

As the deadline of 4 April 2019 for the second annual gender pay report looms, the last few months have seen a flurry of reports and guidance published by the Equality and Human Rights Commission (EHRC), the Government Equalities Office (GEO), the Business, Energy and Industrial Strategy Committee (BEIS Committee) and the government focussed on how best to close the gap. 

Last year 100% of employers in scope reported their gender pay gap (GPG) data.  Recent research commissioned by the GEO found that more companies have prioritised reducing their GPG and 69% of employers now view closing the GPG as a high or medium priority.  So far, about 10% of employers have submitted their reports ahead of the April deadline.   However, according to an analysis of those reports by the BBC on 19 February, four in ten companies have reported a wider gender pay gap compared to last year including Kwik Fit, Npower and Virgin Atlantic.  It remains to be seen whether this is the pattern that emerges when the other 90% of employers submit their reports.       

We look at the recent guidance, best practice for 2019 and the future of gender pay gap reporting.

Guidance and action plans

In December 2018 the EHRC published its report Closing the gender pay gap which was preceded by GEO guidance published in October 2018 Reducing the gender pay gap and improving gender equality in organisations – read more here.

The GEO published two further guides in February 2019.  The first, Eight ways to understand your organisation’s gender pay gap,  looks at key questions to help diagnose the potential specific causes of an employer’s GPG.  It looks at potential areas for improvement from recruitment and promotion to through to termination and the steps an employer should consider where a gender balance is identified so that it can target resources more effectively. 

The key questions include looking at:

• Whether people get “stuck” at certain levels by examining the employer’s own organisational structure including their seniority structure.
• Whether there is a gender imbalance in the organisation’s promotions by comparing the gender ratios of those that apply for promotion with the composition of men and women at the grade below.
• Whether women are more likely to be recruited into lower paid roles by looking at the proportion of women applying for positions and whether there are gender imbalances at different levels or grades.  
• Whether men and women leave the organisation at different rates by looking at the percentages of men and women leaving each year by seniority level.  
• Whether the organisation is doing all it can to support part-time employees to progress and to support both men and women to take on caring responsibilities. 

The second guide Four steps to developing a gender pay gap action plan is based on feedback from employers with successful action plans.  The four steps are:

• To analyse the data and identify actions by understanding why the organisation’s GPG exists. 
• To consult and engage by gaining buy-in from senior people and by involving a wide range of stakeholders.
• To revise, assess and embed the action plan by monitoring and evaluating it so that it can evolve and develop over time. 
• To allow enough time for the process.   

Best practice for 2019 gender pay reports