If you’re responsible for a UK organisation with 250 or more employees, gender pay gap (GPG) reporting is something you need to get right. It’s a legal requirement—and missing the deadline can mean fines and a very public late badge on the government reporting service.
Under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017, eligible employers must calculate and publish specific gender pay gap figures annually. The requirement applies based on employee headcount at a defined snapshot date, not across the whole year—and misunderstanding that detail is where many organisations go wrong.
That said, getting it right isn’t just about avoiding penalties. Done well, GPG reporting is a genuine chance to understand your organisation better, spot pay disparities you might’ve missed, and take the steps that move you toward fairer pay practices.
So, let’s start at the beginning, covering everything from what it is to who has to report gender pay gap.
What is gender pay gap reporting?
Gender pay gap reporting was introduced in the UK in 2017. It requires larger employers to publish specific data about pay differences between male and female employees—making that transparency a legal necessity rather than a nice-to-have.
The idea is to shine a light on pay inequalities and encourage organisations to do something meaningful about them, not just acknowledge they exist.
Who has to report gender pay gap?
If you employ 250 or more people, you must publish your gender pay gap data every year. This applies across the board to private sector, public sector, charities, and voluntary organisations.
The 250-employee threshold is assessed on your snapshot date—5 April for private and voluntary sector employers, and 31 March for most public authorities. If you have 250 or more relevant employees on that specific date, you are legally required to report for that year.
Fewer than 250 employees? You’re not legally required to report. That said, a lot of smaller organisations choose to report voluntarily—it can be a straightforward way to show your commitment to pay equality, and it demonstrates transparency to both employees and candidates.
What is the snapshot date?
Your gender pay gap calculations must be based on pay data from a specific snapshot date each year:
- 5 April for private, voluntary, and most public sector employers
- 31 March for most public authorities
The snapshot date determines:
- Your headcount threshold
- The hourly pay data used for calculations
- The 12-month bonus period
After the snapshot date, you have 12 months to publish your report.
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Working out your headcount
Not sure whether you’ve hit that 250 threshold? It’s not always as straightforward as it sounds—especially if your workforce includes different contract types.
Here’s what needs to be included in your total headcount:
- All employees with a contract of employment: This includes part-time workers, job-sharers, and people on leave (maternity, paternity, sick leave, and so on).
- Partners on a salary: If you’re a partnership and your partners receive a salary, they need to be included.
- Members of a limited liability partnership (LLP): But only if they’re treated as employees for payroll purposes.
It’s important to note that the threshold is based on the number of relevant employees, not just full-time staff. This includes employees on leave and those working part-time hours. Employers sometimes mistakenly exclude staff on maternity leave or long-term sick leave when calculating headcount—but they still count toward the 250 threshold.
Once you’ve counted everyone who fits these categories and you’ve reached 250 or more, you’ll need to report. Looking for more guidance? Check out our Gender Pay Gap Reporting guide.
Who should be excluded from your gender pay gap calculations?
Getting the right people in (and the right people out) of your gender pay gap calculations is crucial. Include the wrong employees and you risk distorting your figures—which means inaccurate reporting and potential compliance issues.
Here’s who should not be included:
- Self-employed contractors: If someone is self-employed and invoices you for their services, they don’t go into your GPG report.
- Agency workers not paid through your payroll: If the agency pays them directly, they’re not included. However, if you pay them directly and deduct tax via PAYE (Pay As You Earn), that changes things—they might count.
- Partners not treated as employees: If partners in your business aren’t paid via payroll as employees, they’re excluded.
- Employees not receiving full pay during the snapshot period: If someone is on reduced or zero pay—for example, on statutory maternity pay or unpaid leave—they’re excluded from hourly pay calculations. They may still need to be included in bonus calculations depending on the circumstances.
- Overtime payments: Overtime is excluded from hourly pay calculations. Only ordinary pay applies here.
It’s good practice to run internal checks before you finalise your figures. The integrity of your data matters, not just for compliance, but for getting a true picture of pay in your organisation.
Director sign-off and legal compliance
In the UK, GPG reports must be signed off by an appropriate senior person. That means a director or equivalent. It can’t be delegated to HR or payroll.
Depending on your organisation type, the right signatory is:
- A director: for companies
- A partner: for LLPs
- A chief executive or equivalent: for public sector bodies
- A trustee or equivalent senior role: for charities and voluntary organisations
What must the statement confirm?
The signatory must confirm in writing that the GPG information (whether that’s your report, your narrative, or action plan) published is accurate to the best of their knowledge and belief. This is a legal declaration—and signing off on inaccurate data carries very real reputational and legal risk, both for the individual and the organisation.
Why this matters
Director sign-off exists to embed accountability at board level. It signals that GPG reporting isn’t an administrative tick-box exercise. It’s a matter of senior leadership responsibility. Organisations that treat it that way, with proper governance and board visibility, tend to be better placed to take meaningful action on the underlying gap too.
What happens if you don't comply?
Enforcement sits with the Equality and Human Rights Commission (EHRC). The EHRC has the power to investigate non-compliant organisations and pursue court orders requiring compliance. While formal enforcement action has historically been limited, this is an area of increasing scrutiny—and the reputational consequences of failing to report, or reporting inaccurately, are significant.
Employees, investors, and the media routinely monitor GPG data. Organisations that fail to report, report late, or publish figures that seem at odds with their workforce face serious reputational risk—and that’s not something enforcement action alone can fix.
Who has to report gender pay gap? Answered!
If you’d like to see how Cintra’s payroll software makes gender pay gap reporting straightforward—including monitoring your data throughout the year—we’d be happy to walk you through it, book a demo now.
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