Final Gender Pay Gap Reporting Regulations eagerly awaited
Gender Pay Gap Reporting is being implemented as part of the Government’s pledge to “end the gender pay gap in a generation”. The intention is to encourage larger employers to take steps to address gender pay inequalities by forcing them to publish their gender pay gap statistics.
The Government published a consultation and draft Regulations in February this year, to which they received approximately 150 responses (including BLP’s response). We expect the Government’s own response to its consultation during the summer, possibly very shortly. The final Regulations and guidance for employers are also expected soon. It is anticipated that the final Regulations will be published in good time before the commencement date, which the Government is currently planning to be April 2017.
Expect some changes to the final legislation
The issues we expect the Government to clarify in the final Regulations and in guidance include:
- whether the reporting requirements will apply to individual employers within a group, or on a group-wide basis;
- expanding the types of UK staff who will fall within the pay gap reporting net; and
- clarifying whether and how certain elements of pay and bonuses need to be included when calculating gender pay gaps.
What employers can do now
Whilst some changes are expected to the final Regulations, there is much employers can do now to start preparing for the new reporting requirements. This includes:
- putting together a gender pay gap reporting implementation team (which will need to have input from various stakeholders such as HR, Payroll and your legal team);
- obtaining buy-in from those at the top of your organisation – the Regulations require sign off from a senior executive; and
- considering doing a ‘dummy run’ pay gap analysis, to give you a head start on identifying significant pay gaps, to aid your thinking on how to manage them.
BLP’s Employment Group is monitoring progress on the implementation of the Regulations and we will keep you informed of the latest developments.