An employer in England, Scotland or Wales with 250 or more staff on the year’s snapshot date must report its gender pay gap. It files the figures on the government’s gender pay gap service, publishes them on its own website, and keeps them online for at least three years. From 2027 it will also have to publish an action plan.
What the gap measures
The government defines the gender pay gap as how far men’s average pay in an organisation differs from women’s. The CIPD describes it as a comparison of men’s and women’s median hourly pay. That makes it a different thing from equal pay, which the Equality Act 2010 covers and which requires equal pay for work of equal value.
A gap can run either way. The CIPD gives the example of a 13.9% gap, meaning women earn less per hour on average, and a gap of −9.2%, meaning they earn more. Its worked example is Avocet Care, a dementia care firm with 305 staff. Its figures favour women because only three of its senior staff are men, while its low-paid drivers and maintenance staff are men.
What goes in the report
The data goes on the gender pay gap service once the employer has done its calculations. It must also appear on the employer’s website, or on an intranet or a parent company’s site if it has no website, and staff must be told where to find it.
Private and voluntary sector employers add a written statement confirming the figures are accurate. An “appropriate person”, usually a director, partner or senior officer, signs it. Most public authority employers do not need one.
Any employer may add a supporting narrative. GOV.UK suggests it can explain why the gap exists, what the employer has done to close it, and why some steps take time to show. Public authorities in Scotland and Wales follow different rules.
What changes in 2027
Action plans are voluntary for now. Acas says they become mandatory in 2027 for employers with 250 or more workers, under the Employment Rights Act 2025. GOV.UK puts the date at spring 2027, subject to legislation.
A plan sets out the steps an employer is taking on its pay gap and on supporting staff through menopause. Acas says each employer must pick at least one action, from a list the Office for Equality and Opportunity publishes.
What happens to an employer that misses it
Missing the deadline breaks the law. The Equality and Human Rights Commission can take enforcement action over late or inaccurate data, which can end in court orders and fines. A late employer also gets a “late badge” on the public service for each year it failed to report.
