All organisations employing 250 employees or more are required to publish the raw data setting out their gender pay gap by 4 April 2018 for private companies and 30 March 2018 for public organisations.
The government set up a website to capture this information. So far, only 20 organisations have posted their results and, of these, only 1 government department has done so.
Whilst you can leave publication until the last minute, we don’t recommend that you do so. In fact, once you have crunched the numbers and properly considered the causes behind the pay gap and agreed a strategy to address these, you should go ahead and publish.
You must also publish your findings on your own UK website, in English, in a manner that is accessible to all employees and the public, and once published it must remain there for at least three years. You don’t have to provide this information in a prominent place on your homepage but it should not be “buried” either.
There is no need to do anything other than provide the required data. However, it is worth considering including a short narrative to provide context and set out the steps your organisation is taking to narrow the gap or at least to explain why there is a gap. The starting point is to consider how your figures compare to the national average and, separately, those in your industry if that information is available.
If your figures compare favourably to the national average, you might want to flag this to demonstrate that your business is already “ahead of the curve”. If some of your figures are higher than the national average, you may want to explain the reason for this, particularly if it is only focussed in one part of the business to avoid creating the impression that you have a significant gap throughout your organisation as this may put off, for example, applicants who may have wanted to join your organisation.
Remember though, whatever your figures and whatever you say about them will act as a baseline for future years and can be used to show improvements.
Many of our clients have decided against only providing the required data and are opting for more transparency. Being open about the issue, why it has arisen and sharing future plans will provide a positive message even if the data itself could be viewed as disappointing.
The government's mean pay gap – the difference in average salaries for men and women – is 5.3%, and its median pay gap is 5.9%. This compares favourably to the UK’s national average gender pay gap, which is 18.1%, according to the Office for National Statistics.