28 March 2022

Gender pay gap reporting 2022: what’s required?

From the snapshot date and reporting deadline, to where to view other employers’ reports, here’s everything you need to know about gender pay gap reporting


Cathryn Newbery

Cathryn Newbery

Cathryn Newbery is head of content and community at Ciphr. She was previously deputy editor at People Management magazine. You can find her on Twitter @c_newbery.


Corporate governance Diversity and inclusion Talent management


From the snapshot date and reporting deadline, to where to view other employers’ reports, here’s everything you need to know about gender pay gap reporting

We answer some of the most common questions about gender pay gap reports, their effectiveness so far in reducing gender pay inequality, and the prospect of the requirements being extended to a wider group of employers.


Does my organisation have to report its gender pay gap?

The reporting requirements apply to private- and voluntary-sector organisations with a headcount of 250 or more employees at 5 April 2021, and most public-sector organisations with 250 employees or more at 31 March 2021. Acas has guidance to help you determine if the requirements apply to you.


What is the snapshot date for the 2021/22 round of gender pay gap reporting?

The snapshot dates are:

  • 5 April 2021 for private companies and charities
  • 31 March 2021 for public-sector organisations


When do the 2021/22 gender pay gap reports have to be submitted?

You must report and publish your gender pay gap information within one calendar year of your snapshot date. So private companies and charities must report their 2021 data by 5 April 2022, and public-sector organisations must report by 31 March 2022.


Can the data be submitted earlier than the deadline date?

Yes, gender pay gap reports can be submitted any time after the snapshot data, up to and including the deadline date.

Around 6% of organisations that had to publicly report their gender pay gap figures for 2017 did so after the spring 2018 deadline. 100% compliance was only achieved in August 2018. In April 2019, around a quarter of organisations filed their data in the final 36 hours before the submission deadline.


What data has to be submitted?

Organisations must calculate and publish:

  • Their mean gender pay gap
  • Their median gender pay gap
  • Their mean bonus gender pay gap
  • Their median bonus gender pay gap
  • The proportion of men who receive a bonus payment
  • The proportion of women who receive a bonus payment
  • The proportion of men and women in each quartile pay band


How do I calculate this data?

The government website has advice about how to calculate the required figures. Good HR systems should be able to calculate this data for you automatically. You may also want to ask your payroll provider for support.


How should employers record data on transgender and non-binary employees?

The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (SI 2017/172) require employers to calculate their gender pay gap by comparing the pay of their male and female employees.

It is worth remembering that ‘sex’ and ‘gender’ are terms that are often used interchangeably but they are in fact two different concepts, even though for many people their sex and gender are the same. Sex is biologically defined, and gender is an individual choice – one that is about self-identification and association.

Employers should generally use the gender identification that they have on record for their employees. Guidance from ACAS has suggested that data for any employees that don’t identify as male or female can be omitted.


Where do I submit my organisation’s gender pay gap?

You must submit your organisation’s data via the UK government’s website.

You also need to publish the data and any supporting narrative you have written in an accessible place on your organisation’s website.


Where can I view and compare data about organisations’ gender pay gaps?

You can browse reports by employer, and compare organisations’ data, on the UK government’s website.


Is the reporting leading to positive change in gender pay gaps?

The most recent data currently available is for 2020-21, when the average gender pay gap of all firms that reported their information was 10.4% – the same as in 2019-20. A total of 9,628 companies reported their pay gaps by the 5 October 2021 deadline (extended from the usual spring deadline because of the impact of the coronavirus pandemic). Of those companies, 13% reported a pay gap in favour of women, and 8% reported no pay gap. In contrast, a September 2021 survey of UK workers by Ciphr found that most people – 59% of women and 52% of men – perceive no pay gap at the organisation they work for.


What are the penalties for failing to report on your gender pay gap?

In May 2019, the EHRC named and shamed 47 organisations that had failed to submit their gender pay gap reports following the March and April 2019 deadlines. It said it would begin formal investigations into their non-compliance, and determine if these organisations were breaking the law by withholding gender pay gap reports. If so, they would be required to publish the data immediately; those which did not comply could be taken to court and issued with an fine.

In June 2019, the EHRC’s chief executive, Rebecca Hilsenrath, told MPs that the body’s lack of power to fine organisations itself was hampering enforcement of the reporting regulations. So we may see changes in the future to how non-compliance with the requirements are prosecuted. As of October 2021, penalties for non-compliance with the reporting requirements have yet to be introduced.


Will smaller organisations, with fewer than 250 employees, ever have to report their gender pay gap reports?

In August 2018, the parliamentary Business, Energy and Industry Strategy (BEIS) committee called for gender pay gap reporting to be widened to include all companies with more than 50 employees. To date, the committee’s recommendations have not been implemented. However, preparing a voluntary report could be a prudent option for companies who are set to grow in employee size to more than 250 people by the next snapshot date.


Will the government ever require organisations to report on other facets of diversity, such as ethnicity?

In October 2018, the government launched a consultation to determine if mandatory reporting of ethnicity pay gaps would help to address pay disparity. In response to the consultation, the Association of Accounting Technicians (AAT) has suggested that any requirements to report ethnicity pay gaps should apply to organisations with 50 or more employees.

The Institute for Public Policy Research, a think tank, has called for pay gap reporting to be extended to cover disability pay gaps as well.

In June 2019, Hilary Spencer, director of the Government Equalities Office, told MPs that there was “probably an argument” for changing the reporting requirements from year four (2021) and that there would be a formal review of the legislation in 2022. In September 2021, the CIPD urged the UK government to make ethnicity pay gap reporting mandatory for all large employers from April 2023.

New regulations that require some large UK companies to report their executive pay ratios was announced in January 2019, and the first reports were published from January 2020 onwards.

This article was first published in January 2019. It was updated in August 2019, March 2020, July 2020, August 2021, October 2021, and March 2022. 

Need help calculating your gender pay gap reports? Call us on 01628 814242 to find out how Ciphr can quickly and easily calculate this data for you