Private, voluntary and other employers
SI 2017/172, snapshot 5 April, deadline 4 April, signed written statement.
reg 1(2)Gender pay gap · Requirements · UK
Gender pay gap reporting requirements UK: six figures, one statement, one deadline
Gender pay gap reporting requirements in the UK apply to every employer in Great Britain with 250 or more employees on its snapshot date, under the Gender Pay Gap Information Regulations 2017 and, for most public authorities, SI 2017/353.
Each year the employer publishes six figures and a signed statement on its own website and on the government’s gender pay gap service, within 12 months of the snapshot date.
Equality action plans are voluntary for 2026 to 2027, and ethnicity and disability pay gap reporting is still a proposal.
In one table
Gender pay gap reporting requirements, one line each
Every requirement on a private or voluntary sector employer, with the provision it comes from.
Public authorities follow the same pattern under Schedule 1 to SI 2017/353, with a 31 March snapshot date.
| Requirement | What it means | Provision |
|---|---|---|
| Test the headcount | 250 or more employees on 5 April, counted per legal entity | reg 1(2) |
| Use the relevant pay period | The pay period in which the snapshot date falls, for hourly pay | reg 5(2) |
| Use the bonus period | Bonus pay in the 12 months ending with the snapshot date | regs 10(2), 11 |
| Calculate six items | Mean and median hourly pay gap; mean and median bonus gap; bonus proportions; quartile bands | reg 2(1)(a)–(f) |
| Sign a written statement | Confirms the information is accurate; signatory set by type of employer | reg 14 |
| Publish on your own website | Accessible to employees and the public, for at least three years | reg 15(1) |
| Publish on the government website | The six items and the signatory’s name and job title | reg 15(2) |
| Meet the deadline | Within 12 months of the snapshot date: by 4 April | reg 2(2) |
| Repeat every year | For every year you have 250 or more employees on the snapshot date | reg 2(1) |
Gender pay gap reporting is one of several statutory UK disclosures, all mapped on the sustainability reporting requirements hub.
Who
The 250-employee test on the snapshot date
A relevant employer is one “who has 250 or more employees on the snapshot date”, under regulation 1(2) of SI 2017/172.
The snapshot date is 5 April in the year the information relates to.
Regulation 1(6) carves out bodies listed in Schedule 19 to the Equality Act 2010, government departments and the armed forces, because public authorities have their own duty.
That duty is Schedule 1 to SI 2017/353, which applies to a listed public authority with 250 or more employees on 31 March.
The floor is in the enabling Act too: section 78(2) of the Equality Act 2010 disapplies the power for employers with fewer than 250 employees.
The count is a headcount of individuals, not full-time equivalents, and GOV.UK’s guidance says each separate legal entity in a group is tested and reports on its own.
An employer in Great Britain with 250 or more employees on its snapshot date
Public authorities in Schedule 2 to SI 2017/353
Schedule 1 duty, snapshot 31 March, deadline 30 March.
Sch 1 para 1Public authorities in Scotland and Wales
Different rules under the devolved specific duties; GOV.UK points to separate guidance.
GOV.UKCounting
Who counts towards the 250
| Worker | In the headcount? | In the pay calculations? |
|---|---|---|
| Employees on a contract of employment, full or part time, job-sharers | Yes, one each | Yes |
| Employees on leave at full pay | Yes | Yes |
| Employees on reduced or nil pay because of leave | Yes | Bonus calculations only |
| Self-employed people who must do the work personally | Yes | Yes, where the data is held or obtainable |
| Salaried partners and LLP members treated as employees for payroll | Yes | No |
| Equity partners and LLP members sharing profits | No | No |
| Agency workers | No — counted by the agency | No |
| Apprentices, seasonal, temporary, casual and zero-hours employees | Yes, if employees on the snapshot date | Yes |
Length of service does not matter: the guidance says to include an employee even if they had worked for one day before the snapshot date.
Staff working outside Great Britain are included where their employment has a stronger connection to British employment law, and an employer based outside Great Britain may have to count staff working there.
An employer with more than one payroll merges them and reports one set of figures.
What
The six calculations and how each is expressed
Regulation 2(1) lists six items, and regulations 8 to 13 fix the method for each.
Hourly pay figures use full-pay relevant employees only: those not paid at a reduced rate or nil during the relevant pay period because of leave.
Ordinary pay is basic pay, allowances, pay for piecework, pay for leave and shift premium pay, before deductions at source; overtime, redundancy pay, pay in lieu of leave and benefits in kind are excluded.
Bonus pay is money, vouchers, securities or options relating to profit sharing, productivity, performance, incentive or commission.
The quartile bands are formed by ranking full-pay employees by hourly pay and dividing them into four sections of, so far as possible, equal size, under regulation 13.
GOV.UK’s calculation guidance allows figures as whole percentages or rounded to one decimal place, and says the employer is responsible for accuracy even where a third party does the calculations.
Since its May 2026 update, the data guidance says reporting must be based on employees’ biological sex, and that employers without that data should take reasonable and proportionate steps to obtain it.
- 1
Mean hourly pay gap
Difference in mean hourly pay of full-pay men and women, as a percentage of men’s (reg 8).
- 2
Median hourly pay gap
The same, at the median (reg 9).
- 3
Mean bonus gap
Difference in mean bonus paid in the 12 months to the snapshot date (reg 10).
- 4
Median bonus gap
The same, at the median (reg 11).
- 5
Bonus proportions
The proportion of men and of women who received any bonus pay (reg 12).
- 6
Quartile pay bands
Proportions of men and women in four equal bands ranked by hourly pay (reg 13).
Sign-off
The written statement, and who signs it
| Type of employer | Signatory | Provision |
|---|---|---|
| Company or other body corporate (not an LLP) | A director, or equivalent | reg 14(2)(a) |
| Limited liability partnership | A designated member | reg 14(2)(b) |
| Limited partnership | A general partner | reg 14(2)(c) |
| Any other partnership | A partner | reg 14(2)(d) |
| Unincorporated body other than a partnership | A member of the governing body or a senior officer | reg 14(2)(e) |
| Any other type of body | The most senior employee | reg 14(2)(f) |
The statement must confirm that the information is accurate, and the signatory’s name and job title go on the government service with the figures.
The EHRC’s publication guidance says the written statement is required of private, voluntary and public-authority employers not specified in Schedule 19, so most listed public authorities publish figures without one.
A supporting narrative explaining the figures is optional, and many employers use it to connect the numbers to their wider ESG governance.
Where and when
Two places to publish, one 12-month window
Regulation 15(1) requires the information and the statement on the employer’s own website, accessible to all its employees and to the public, for at least three years from publication.
Regulation 15(2) also requires publication on the website designated by the Secretary of State, which is the gender pay gap service.
Regulation 2(2) sets the deadline as the period of 12 months beginning with the snapshot date.
That gives 4 April for private and voluntary employers and 30 March for most public authorities, as the GOV.UK timetable sets out.
The figures can be submitted at any time up to the deadline.
An employer whose headcount has fallen below 250 should tell the service it is out of scope, so it is not marked late.
Enforcement
No fine in the Regulations, but the EHRC can go to court
| Step | What happens | Power |
|---|---|---|
| Warning | The EHRC writes to employers that have failed to report | EHRC policy |
| Investigation | Terms of reference, evidence, a draft report and at least 28 days for representations | Equality Act 2006 s.20 |
| Unlawful act notice | Requires a draft action plan to remedy the breach; appealable within six weeks | s.21, s.22 |
| Agreement | The employer undertakes to comply, in place of further action | s.23 |
| Court order | Requiring an action plan, or compliance with one | s.22(6) |
| Offence | Failing to comply with the court order: an unlimited (level 5) fine on conviction | s.22(6) order |
| Public authorities | Assessment and compliance notice under the public sector duty | ss.31, 32 |
The Explanatory Note to SI 2017/172 says a failure to comply “constitutes an ‘unlawful act’ within the meaning of section 34 of the Equality Act 2006”.
The Act allowed a criminal offence with a level 5 fine under section 78(5)(a), but the Regulations did not create one.
The EHRC says details of any employer it investigates are made public on its website.
Myths
What gender pay gap reporting does not require
It does not require an employer to close its gap, set a target or explain its figures.
It does not require a narrative, group-level figures or a breakdown by grade or site, though all are allowed.
It does not, as at 11 October 2026, require an action plan, an ethnicity pay gap or a disability pay gap.
It is not an equal pay audit: a pay gap compares averages across the workforce, while equal pay is a separate right to equal pay for equal work.
It is not part of the strategic report, though the Companies Act statement on employee matters is covered on the non-financial reporting requirements page.
Common errors in published summaries
“250 full-time equivalents” — the test is a headcount of individuals.
“Fines of up to £…” — no fine is set in the Regulations.
“One report per group” — each legal entity with 250 or more employees reports.
“Action plans are already compulsory” — they are voluntary for 2026 to 2027.
What is changing
Action plans, outsourcing, and ethnicity and disability proposals
Section 33 of the Employment Rights Act 2025 inserted section 78A into the Equality Act 2010, in force from 6 April 2026 under SI 2026/323.
It is a power: regulations “may require” employers with 250 or more employees to publish an equality action plan on gender equality, including addressing the gender pay gap and supporting employees going through the menopause.
The GOV.UK action plan guidance lets employers publish a voluntary plan, with at least one action on the pay gap and one on menopause, by 30 March or 4 April 2027.
GOV.UK says that, “subject to legislation”, plans “will become mandatory from spring 2027”, which is a stated intention until the regulations are made.
Section 34 of the same Act lets future regulations require an employer to publish who supplies its contract workers, and the government’s factsheet says that measure depends on wider pay gap reforms.
On ethnicity and disability, the government consulted from 18 March to 10 June 2025 and published its response on 25 March 2026.
The proposal mirrors gender pay gap reporting for employers with 250 or more employees: the same six calculations, the same snapshot dates, workforce composition, declaration rates and actions in the equality action plan.
The Annex A clauses are “draft only, and may be subject to further refinement”, and as at 11 October 2026 no Equality (Race and Disability) Bill has been passed.
The government’s impact assessment says it intends the regime to be operational by 2029, enforced by the EHRC.
Status at 11 October 2026
In force: the gender pay gap duty, and the section 78A power.
Voluntary: equality action plans for 2026 to 2027.
Proposed: mandatory action plans from spring 2027, the outsourcing disclosure, and ethnicity and disability pay gap reporting.
Alongside
Gender pay gap reporting requirements beside the other UK regimes
Each UK disclosure has its own scope test, so an organisation cannot assume it is in or out of one by analogy with another.
The modern slavery statement turns on a £36 million turnover test, set out on the modern slavery reporting requirements page.
Energy and carbon reporting under SECR applies when a company exceeds two of the size limits, covered on the SECR reporting requirements page.
The social pillar of an ESG report usually draws on the pay gap figures, which the ESG reporting requirements page places among the other statutory sources.
The EU’s sustainability reporting standards include workforce pay metrics for companies within the CSRD, described on the CSRD reporting requirements page.
For listed companies, UK SRS S1 is about sustainability-related financial risks, not workforce pay statistics, as the UK SRS S1 guide explains.
Public-sector bidders weighing social value commitments can read the social value model page, and the wider ESG pillars page shows where pay equity sits.
Check yourself
Six statements about the gender pay gap rules
Each answer names the provision or guidance it turns on.
The duty itself is short: count, calculate six figures, sign, publish twice, and repeat each year.
Most errors come from the count and the data, which is why GOV.UK’s data guidance is worth reading before the calculations.
True or false?
An employer with 250 full-time-equivalent staff but 270 individual employees on 5 April must report.
A private company’s snapshot date is 31 March.
The Regulations set a £5,000 fine for missing the deadline.
A parent company may file one report covering all its UK subsidiaries instead of separate ones.
The figures must stay on the employer’s own website for at least three years.
Ethnicity pay gap reporting became law with the Employment Rights Act 2025.
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Frequently asked
Gender pay gap reporting requirements, answered
Who has to report their gender pay gap in the UK?
Any employer in Great Britain with 250 or more employees on its snapshot date.
Private and voluntary sector employers, and public bodies not listed for the public sector duty, are covered by SI 2017/172 with a 5 April snapshot date.
Most public authorities in England, and listed cross-border bodies, are covered by SI 2017/353 with a 31 March snapshot date. Each legal entity in a group is tested and reports separately.
How do you count the 250 employees for gender pay gap reporting?
By headcount, not full-time equivalents, on the snapshot date.
GOV.UK’s guidance counts everyone with a contract of employment, including part-time staff, job-sharers and people on leave, some self-employed people who must do the work personally, and salaried partners or LLP members treated as employees for payroll.
Agency workers count for the agency that supplies them, not the client.
What are the six gender pay gap calculations?
The mean and median gender pay gap in hourly pay, the mean and median gender pay gap in bonus pay, the proportion of men and of women who received bonus pay, and the proportion of men and women in each of four quartile pay bands.
They are set out in regulation 2(1)(a) to (f) of SI 2017/172, with the method for each in regulations 8 to 13.
What is the gender pay gap reporting deadline?
Within 12 months of the snapshot date.
For private, voluntary and most other employers, the snapshot date is 5 April and the deadline is 4 April the following year.
For most public authorities in England the snapshot date is 31 March and the deadline is 30 March the following year.
Where must gender pay gap information be published?
In two places.
On the employer’s own website, accessible to employees and the public, for at least three years from publication, and on the government’s gender pay gap service, together with the name and job title of the person who signed the written statement.
Who signs the gender pay gap written statement?
Regulation 14 of SI 2017/172 sets the signatory by type of employer: a director or equivalent for a company, a designated member for an LLP, a general partner for a limited partnership, a partner for another partnership, a member of the governing body or a senior officer for an unincorporated body, and the most senior employee for any other body.
The statement must confirm that the information is accurate.
Is there a fine for not reporting the gender pay gap?
There is no fixed fine in the Regulations.
Failing to comply is an unlawful act within section 34 of the Equality Act 2006, which the Equality and Human Rights Commission enforces through investigations, unlawful act notices, action plans and court orders.
Failing to comply with a court order is an offence punishable by an unlimited fine.
Do employers with fewer than 250 employees have to report?
No. Section 78(2) of the Equality Act 2010 disapplies the power for employers with fewer than 250 employees.
GOV.UK’s guidance says smaller employers can still report voluntarily.
Does gender pay gap reporting apply in Northern Ireland?
The 2017 Regulations apply in England, Scotland and Wales.
GOV.UK’s guidance says an employer based in Northern Ireland may still have to count and include employees working in Great Britain if it has 250 or more of them there.
Do group companies report once for the whole group?
No. Each separate legal entity with 250 or more employees must calculate, report and publish its own figures.
A group that has reported for each entity may also publish combined group figures and a supporting narrative, but these are voluntary.
Is a gender pay gap narrative or action plan required?
A narrative is optional.
An equality action plan covering the gender pay gap and menopause support is voluntary for the 2026 to 2027 reporting year; GOV.UK says that, subject to legislation, action plans will become mandatory from spring 2027.
The power to require them is section 78A of the Equality Act 2010, in force since 6 April 2026, and it needs regulations before it binds anyone.
Is ethnicity pay gap reporting mandatory in the UK?
Not yet.
On 25 March 2026 the government published its response to the consultation on mandatory ethnicity and disability pay gap reporting for employers with 250 or more employees, with indicative draft clauses.
Those clauses are a proposal: as at 11 October 2026 no Equality (Race and Disability) Bill has been passed, and the government’s impact assessment says it intends the regime to be in place by 2029.
Is disability pay gap reporting required?
No, not as at 11 October 2026.
The government’s proposal, set out in its March 2026 response, would mirror gender pay gap reporting for disability and ethnicity, add workforce composition and declaration rates, and fold actions into equality action plans. It needs primary legislation and regulations first.
Is the gender pay gap the same as equal pay?
No. The gender pay gap compares the average pay of men and women across an organisation.
Equal pay is the separate legal right under the Equality Act 2010 for men and women to be paid the same for equal work; a gender pay gap report does not by itself show an equal pay breach.
What counts as bonus pay for the gender pay gap?
Remuneration in money, vouchers, securities or options that relates to profit sharing, productivity, performance, incentive or commission, paid in the 12 months ending with the snapshot date.
Ordinary pay, overtime and redundancy or termination pay are excluded.
How does gender pay gap reporting relate to ESG reporting?
It is a separate statutory duty under equality law, not part of the climate or sustainability reporting regimes.
Many companies cite their gender pay gap figures in the social section of an annual report or ESG report, and the Companies Act non-financial and sustainability information statement asks larger companies to cover employee matters, but neither replaces the filing on the government service.
Sources
Primary sources
Every figure, date and status on this page traces to the instrument’s owner.
Secondary commentary is never the source for a number.
Checked against 27 sources fromlegislation.gov.ukGOV.UK (Office for Equality and Opportunity)GOV.UKDepartment for Business and TradeEquality and Human Rights CommissionGOV.UK (Cabinet Office)
- legislation.gov.ukThe Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (SI 2017/172)
The duty for private, voluntary and most other employers; in force 6 April 2017.
- legislation.gov.ukSI 2017/172, regulation 1 — the 250-employee test and the 5 April snapshot date
Who is a relevant employer, and the public-sector carve-out in reg 1(6).
- legislation.gov.ukSI 2017/172, regulation 2 — the six items and the 12-month deadline
Regs 2(1)(a)–(f) and 2(2).
- legislation.gov.ukSI 2017/172, regulation 14 — the signed written statement
Who signs, by type of employer.
- legislation.gov.ukSI 2017/172, regulation 15 — form and manner of publication
Own website for at least three years, and the government website.
- legislation.gov.ukThe Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017 (SI 2017/353)
The public authority duty; in force 31 March 2017.
- legislation.gov.ukSI 2017/353, Schedule 1 — gender pay gap reporting by public authorities
The 31 March snapshot date and the same six items.
- legislation.gov.ukEquality Act 2010, section 78 — gender pay gap information
The enabling power, and the 250-employee floor in s.78(2).
- legislation.gov.ukEquality Act 2010, section 78A — equality action plans
Inserted from 6 April 2026; a power to make regulations.
- legislation.gov.ukEmployment Rights Act 2025, sections 33 and 34
Equality action plans, and information about outsourced workers.
- legislation.gov.ukSI 2026/323, regulation 3(7)
Section 33 in force on 6 April 2026.
- legislation.gov.ukEquality Act 2006, sections 20 to 24 — enforcement powers
Investigations, unlawful act notices, action plans and agreements.
- GOV.UK (Office for Equality and Opportunity)Gender pay gap reporting: guidance for employers
Statutory guidance, updated 21 May 2026.
- GOV.UKWho needs to report
Headcount, legal entities, partners, agency workers and overseas staff.
- GOV.UKWhen to report
Snapshot dates and the 30 March and 4 April deadlines.
- GOV.UKPreparing your data
The relevant pay period, and reporting by biological sex.
- GOV.UKMaking your calculations
The six calculations, and rounding to one decimal place.
- GOV.UKGender pay gap reporting and creating an action plan: guidance collection
Action plans voluntary now; “subject to legislation” required from spring 2027.
- GOV.UKCreating an action plan: overview
At least two actions; 2026-27 deadlines.
- GOV.UKGender pay gap service
The government website designated for submissions.
- Department for Business and TradeEquality action plans and outsourcing factsheet (PDF)
Timing of action plans and the outsourcing measure.
- Equality and Human Rights CommissionGender pay gap: our enforcement action
Warning notices, investigations, unlawful act notices, court orders.
- Equality and Human Rights CommissionOur enforcement powers
Sections 20–24, 31 and 32 of the Equality Act 2006.
- Equality and Human Rights CommissionStep 3: publish your gender pay gap report
What to publish, where, and for how long.
- GOV.UK (Office for Equality and Opportunity)Equality (Race and Disability) Bill: mandatory ethnicity and disability pay gap reporting — consultation and response
Consultation 18 March – 10 June 2025; response 25 March 2026.
- GOV.UKAnnex A: draft primary legislation
Indicative clauses only, “subject to further refinement”.
- GOV.UK (Cabinet Office)Final stage impact assessment: mandatory ethnicity and disability pay gap reporting
The government’s intention for the regime to be in place by 2029.
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