10 things you might not know about UK gender pay gap reporting

14th November 2025

Staff member Julia

Julia Hanna

We may be hurtling towards the end of 2025, but the gender pay gap is still alive and kicking.

Recent UK Government figures show that although the gender pay gap has fallen by more than a quarter among full time employees in the last decade (to 6.9% median), the overall UK mean gender pay gap remains 13.4% in favour of men.  So, although it is decreasing slowly over time, there’s still some work to be done.

The live nature of the issue means it is incredibly important gender pay gap reporting is accurately carried out.

Today, in the final of our series of ‘Top 10’ blogs written to celebrate our ten-year anniversary, we look at ten things you might not know about gender pay gap reporting in the UK:

1. Pay gaps are about parity, not pay

The gender pay gap is very different to equal pay.  Pay is simply the unit used to measure the relative seniority of men and women across an organisation. 

As the pay gap is determined by the difference between average pay for male employees, compared to average pay for female employees, you can actually have a zero pay gap yet still have unequal pay.  Similarly, you can have a significant pay gap whilst having equal pay.  

2. Be careful when you pay bonuses

If paid at the ‘wrong’ time, bonuses can be double-counted as both bonus, and as part of ‘ordinary pay’.  

This happens if they are paid in the pay period that straddles the snapshot date of 5 April for private/voluntary, and 31 March for public sector.   This can impact your gender pay gap.

3. Your bonus year and pay snapshot date might not align

Depending on timing, your bonus year and pay snapshot date may not align as you think they should.  As bonus gaps relate to bonuses paid in the 12 months preceding the snapshot date, they could relate to the previous performance year.  

4. There are some calculation quirks in the regulations

Cars and car allowances are treated differently.  Car allowances are cash and therefore included in GPG calculations, but company cars are non-cash benefits and are excluded.

Pay is also not quite what it seems: it is calculated after any salary sacrifice deductions have been taken out. 

Bonuses are also a tricky one as they are actual bonuses paid, and not FTE bonuses.  So, the gap can be impacted by part time working.  

5. Your initiatives may actually make your gap worse

As you take action to close your pay gaps, they could very well get worse before they get better.

Many action plans include gender balanced intake at entry or graduate level.  This balance will take time to work through the organisation and, whilst it does, you may have a greater proportion of females in the entry levels than you had before the action was taken. This will increase your pay gap in the short term.

6. Equality action plans are likely to be mandatory

Although Equality Action Plans are currently voluntary, proposed regulations in both Northern Ireland and Labour’s Employment Rights Bill will change that and require employers to publish the steps to be taken to narrow pay gaps.

7. Ethnicity and disability reporting is on the horizon

While many forward-thinking organisations are already voluntarily reporting beyond gender, the draft Equality (Race and Disability) Bill plans to extend pay gap reporting to include ethnicity and disability.

So, it’s time engage with employees to disclose their background and improve your declaration rates before the analysis has to be done.

8. Partnerships can exclude Partners

As Partners are not employees, they are currently excluded from the regulatory calculations. However, that doesn’t necessarily provide an authentic reflection of the organisation as the most senior level is excluded from the analysis.  

Many partnerships voluntarily share additional reporting that includes Partners (usually based on a total cash approach due to different types of packages to employees) to keep within the ‘spirit’ of the regulations. 

9. Outsourced workers may soon be in

Outsourced workers are currently out of scope under the current gender pay gap regulations.  However, the Employment Rights Bill is looking to include them in the future.

10. Pay gap regulations don’t cover Northern Ireland – yet

The Department for Communities has recently set out plans to introduce pay gap regulations in NI. These haven’t gone as far as anticipated with the inclusion of ethnicity and disability gaps on hold for now.

The methodology will broadly follow those in GB but go further with publication of a mandatory action plan.  We don’t yet know the threshold number of employees for reporting as 250 may not be appropriate considering the size of businesses in NI.

Nor do we know the start date (it will be when the ‘Good Jobs Employment Bill’ receives Royal assent), but we anticipate regulations will come into force 2027. As, due to the ‘Windsor Framework’ most aspects of the European Pay Transparency Directive may need to be adopted too.

How we can help

At Verditer, we are specialists in pay equity, including pay gap reporting in the UK, Ireland and across the EU.  Do get in touch if you’d like our help to establish and understand your figures, draft an authentic narrative or employee comms, or create an action plan.

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