Gender pay gap reporting: who must report?

If you work in care, a shop, a warehouse, a kitchen or a hospital, a gender pay gap report can show where women cluster in lower-paid jobs. It cannot tell you whether your own pay is fair. Check your employer’s report today, then write down your role, hours, pay and any colleague doing comparable work. Do not wait for the next report if you think you are underpaid.

Who must report?

Companies, charities, partnerships and public employers in Great Britain can all be covered. Count individuals, not full-time equivalents: two people sharing one job count as two. The test is applied per legal entity, not to the group total. Five private-sector subsidiaries with 200 people apiece do not qualify just because the parent group has 1,000; a subsidiary with 260 reports separately.

If an entity is below 250 on the snapshot date, the annual GB duty does not apply, even if it grows past 250 later. It can still report voluntarily. An employer that reported last year but has dropped below the threshold should update its status on the service to avoid a public late badge. Scottish public bodies also need to check the separate duty below.

How to count the 250

The government’s headcount guidance draws a distinction between the people who trigger the duty and those included in each calculation.

A contractor’s personal-service obligation, not the label on an invoice, matters here. The exception where pay data cannot reasonably be obtained affects the figures, not the headcount. Agency workers supplied to your site belong in their agency’s report. If you operate several payrolls for one legal entity, combine them into one return.

The six measures you must publish

Under the 2017 regulations, employers publish six measures, not six individual numbers. Bonus proportions and each quartile band require separate percentages for men and women:

1. Mean hourly gap. The difference between the average hourly rates for men and women, expressed as a percentage of the men’s average.
2. Median hourly gap. Compare the middle hourly rate for men with the middle hourly rate for women, using the men’s rate as the denominator.
3. Mean bonus gap. Compare average bonuses among men and women who received bonuses in the 12 months ending on the snapshot date.
4. Median bonus gap. Compare the middle bonuses among bonus recipients in that period.
5. Bonus proportions. State what proportion of all relevant men received a bonus and what proportion of all relevant women did.
6. Pay quartiles. Rank full-pay staff by hourly rate, divide into four bands and show the percentage of men and women in each.

The hourly and quartile measures use full-pay relevant employees and the pay period containing the snapshot date. Someone on reduced pay because of leave still counts towards the threshold and in the bonus measures, but not in those hourly or quartile measures. Hourly pay can include a bonus paid in the relevant pay period, apportioned where required; it is not simply base salary divided by contracted hours. Ordinary pay includes basic pay, allowances, piecework, leave pay and shift premium, before deductions. Overtime, termination pay, pay in lieu of leave and non-cash benefits are excluded from ordinary pay.

Where, how and who signs

Publish on your publicly accessible website and leave the information there for at least three years from publication. Submit the same figures to the government service. If you publish on 4 April 2027, keep that report online until at least 4 April 2030; publishing earlier starts the three years earlier.

Employers reporting under the main 2017 regulations must include a written statement confirming accuracy, signed by the appropriate senior person: for a company, a director or equivalent; for an LLP, a designated member; for a partnership, a general partner. The regulations specify other signatories for other bodies. Most listed public authorities reporting under the public-sector regulations do not need this signed statement.

Deadlines for this cycle

For the 2026 snapshots, the reporting periods and deadlines are:

What happens if you don’t report

Failing to report is an unlawful act for the purposes of the Equality and Human Rights Commission’s powers. The EHRC can seek an enforceable agreement, investigate and apply for a court order. An unlimited fine is possible for breaching a court order; there is no automatic fine just because a report is late.

The Commission can also name employers that miss deadlines. Its 2024–25 update reported full compliance after ten initially non-compliant organisations were publicly named. Filing accurate figures matters as much as meeting the date; the statutory declaration of accuracy is not a formality.

Scotland, Wales and Northern Ireland

The annual 250-person reporting regime covers Great Britain, not Northern Ireland. A Belfast-based employer can still be required to report if it has enough staff working in Great Britain. Overseas and seconded workers need an individual jurisdiction assessment: the government’s general test is whether they could bring an Equality Act claim in a GB employment tribunal.

Scotland: Private and voluntary employers follow the GB rules. Under the Scottish Specific Duties, listed public authorities with 20 or more employees during the relevant reporting period also publish gender pay gap information every two years under a separate scheme. Unlike the annual GB duty, its 20-person test is not a single 31 March headcount. Separate equal-pay and occupational-segregation duties also apply.

Wales: The GB gender pay gap rules apply; listed Welsh public bodies have other specific equality duties too. Northern Ireland: no equivalent gender pay gap reporting regulations are in force as at 1 October 2026. Section 19 of the Employment Act (Northern Ireland) 2016 remains prospective. The Department for Communities has consulted on implementing regulations, but a consultation is not a reporting duty. See our Northern Ireland guide for the wider differences.

A pay gap is not an equal-pay claim

A reported gap compares average earnings across an employer’s workforce; it does not compare two people in equivalent jobs. The legal questions differ:

For example, a company might pay every shop-floor employee the same rate but have more men in highly paid management roles: a gender gap without necessarily breaking equal-pay law. Or it might report no overall gap yet underpay one woman compared with a man doing like work. Our equal pay guide explains comparators, defences and claim time limits.

What to do if the figures match your experience: save the report, then note your job title, duties, hours, basic pay, shift premiums, tips or tronc, and any colleague doing work you believe is equal in value. Keep payslips and rotas. Ask your employer in writing how your pay is set. A care worker can note sleep-in shifts; a kitchen porter can record tips and unpaid time; a shop assistant can compare duties and shift premiums. These records do not prove a claim, but they give your union or adviser something concrete to assess. Contact your union, such as UNISON in health and care, USDAW in retail, Unite in hospitality and food, GMB in care and logistics, or IWGB in delivery work. Acas early conciliation is the route before most tribunal claims, and time limits can be short: contact Acas or a law centre now, not when the employer’s report is next updated. Citizens Advice can help you find local advice. If the issue is minimum-wage wage theft, report it to the Fair Work Agency, which took over enforcement on 7 April 2026. Raise safety risks with the HSE, labour exploitation with the GLAA, and systemic discrimination with the EHRC.

What is changing: action plans and wider reporting

The Employment Rights Act 2025 provides for equality action plans, but the enabling power and a duty to file a plan are not the same thing.

1. 6 Apr 2026Enabling power commenced

   Section 33 allows regulations requiring larger employers to publish plans addressing their gender pay gap and support for employees experiencing menopause. It does not itself make plans mandatory. The government service already accepts voluntary plans: its guidance asks for at least two actions, one on each issue.

2. Spring 2027Mandatory plans expected, subject to legislation

   The government intends to make plans mandatory from spring 2027, but the secondary legislation and exact start date were not confirmed as at 1 October 2026. For voluntary plans alongside the 2026 snapshot, GOV.UK gives deadlines of 30 March 2027 for most public authorities and 4 April 2027 for other employers.

Section 34, also enacted but not commenced, would allow future rules requiring certain employers to identify suppliers of outsourced workers; it does not put agency staff into a hirer’s present pay-gap figures. A proposed Equality (Race and Disability) Bill could introduce ethnicity and disability pay-gap reporting, but no such duty is in force as at 1 October 2026 and its start date is unknown.