UK Gender Pay Gap Reporting 2026: Rules, Calculation, Disclosure

UK employers with 250+ staff must publish their gender pay gap annually. The rules cover what to calculate, how to disclose, and (since recent reforms) what narrative explanation to provide. This guide covers the 2026 position for both employers managing the disclosure and employees trying to interpret the figures.

Who must report

UK employers with 250 or more staff on the snapshot date are required to report under the Equality Act 2010 (Specific Duties and Public Authorities) Regulations and the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

The threshold:

• Private + voluntary sector: 250+ employees on 5 April (snapshot date).
• Public sector: 250+ employees on 31 March (different snapshot date).

If you cross or fall below 250 employees mid-year, the snapshot-date headcount determines whether reporting is required for that year.

What you must publish

Six separate metrics must be published annually:

1. Mean gender pay gap - average hourly pay for men minus average for women, expressed as a percentage of the men's average.
2. Median gender pay gap - same, but using the median (middle value) instead of mean.
3. Mean gender bonus gap - same calculation but for bonus payments only.
4. Median gender bonus gap - same.
5. Proportion of men receiving a bonus - percentage of male employees who received any bonus payment in the relevant period.
6. Proportion of women receiving a bonus - same for female employees.
7. Quartile pay distribution - proportion of men/women in the lowest, lower-middle, upper-middle, and upper quartiles of pay.

These figures are published on the employer's website AND submitted to the Government Equalities Office (GEO) at gov.uk/gender-pay-gap-reports.

How to calculate the mean gap

Mean gender pay gap = ((Mean male hourly pay - Mean female hourly pay)
                       / Mean male hourly pay)
                      × 100

A positive percentage means men are paid more on average. A negative means women are paid more on average. Zero means equal pay.

Worked example: company with 50 male employees averaging £30/hour and 50 female employees averaging £25/hour.

Mean male: £30/hour
Mean female: £25/hour
Difference: £5/hour
As % of male: £5 / £30 × 100 = 16.7%

The reported mean gender pay gap is 16.7%.

Why median + mean matter

The Government requires both because they tell different stories:

• Mean is sensitive to outliers. A few very high-paid male executives can push the mean substantially.
• Median is the middle value - less sensitive to outliers, more representative of "the typical employee".

A company with one CEO earning £500,000 + 99 employees earning £25,000 each has a very high mean if the CEO is male (because their salary inflates the male average enormously) but a near-zero median (because the middle value is similar across genders).

The combination reveals structural vs outlier-driven gaps.

Common misinterpretations

Misinterpretation 1 - Same role, different pay

The gender pay gap is NOT about paying men and women differently for the same role. That's equal pay (a separate issue under the Equality Act 2010). Equal pay legislation has been in force since 1970 and is separately enforceable.

The gender pay gap is about the distribution of men and women across roles - typically reflecting that men dominate higher-paid sectors / roles within an organisation.

Misinterpretation 2 - A 0% gap means everything is fine

A 0% gap can mean genuine equality, OR it can mean the company has very few female employees (so the female average is dominated by a small sample). Always look at:

• The headcount (how many men vs women).
• The distribution (which quartiles women occupy).
• Trends over time.

Misinterpretation 3 - A high gap is the company's "fault"

The gap can reflect industry structures (e.g. construction has historically low female representation in skilled trades), regional patterns (rural areas often have less diverse workforces), or recruitment difficulties. The report includes a narrative explaining contextual factors.

Pay quartile reporting

Employers must report what % of men and women fall into each pay quartile:

• Lower quartile: bottom 25% of earners.
• Lower-middle quartile: 25-50% of earners.
• Upper-middle quartile: 50-75% of earners.
• Upper quartile: top 25% of earners.

If women dominate the lower quartile and men dominate the upper quartile, the gender pay gap will be substantial - but the underlying issue is role distribution, not unequal pay for equal work.

What's excluded from the calculation

• Salary sacrifice deductions: included in the post-sacrifice gross used.
• Overtime: typically excluded from the standard "ordinary pay" calculation.
• Leavers during the snapshot period: included if they were active on 5 April.
• Employees on long-term sick or maternity at full pay: included.
• Employees on long-term sick or maternity at reduced/SMP pay: typically excluded (the actual hourly rate is too low to compare meaningfully).

The Government's official guidance covers edge cases.

When the report must be published

• Private + voluntary sector: by 4 April following the 5 April snapshot date.
• Public sector: by 30 March following the 31 March snapshot date.

Late publication or non-publication can trigger:

• Public criticism (most reports are now widely scrutinised).
• GEO enforcement action under the Equality Act.
• Reputational damage affecting recruitment + brand.

What an employee should look at

If you're considering joining or staying at a UK employer with 250+ staff, check their gender pay gap report at gov.uk/gender-pay-gap-reports:

1. What's the mean and median gap? A median gap above 15% suggests structural issues.
2. What's the bonus gap? Often the most extreme - bonuses can compound the structural issues from base pay.
3. What % of men vs women receive a bonus? A massive gap here (e.g. 80% men vs 30% women receiving bonuses) signals systemic favouring.
4. What's the trend over 5 years? Closing gaps suggest active management; widening gaps signal complacency.
5. What's the narrative? Look for specific commitments + actions, not generic platitudes.

What employees can do if their employer's gap is concerning

• Read the narrative alongside the figures.
• Talk to HR about specific concerns.
• Use the data in pay negotiations - if women are concentrated in lower quartiles, you can frame your value differently.
• Consider unionising - the Public and Commercial Services Union (PCS), USDAW, GMB, Unite, and others actively use gender pay gap data in collective bargaining.
• Report internal practices to the Equality and Human Rights Commission (EHRC) if you suspect direct equal-pay violations.

When to talk to an HR / employment law specialist

For routine reporting compliance, large UK employers handle this internally. Specialist advice from an employment law solicitor or HR consultancy is valuable when:

• Your reported gap exceeds industry benchmarks by a significant margin.
• You face shareholder activist pressure on the gap (common for FTSE-listed firms).
• You're considering gender pay equity certification (Government Equalities Office initiative).
• You're an employee suspecting equal pay violations (separate legal route from gap reporting).

The CIPD provides resources at cipd.org/uk/topics/gender-pay-gap. For employment law disputes, ACAS (0300 123 1100) is the first stop.

Disclaimer

PayslipIQ provides automated educational guidance based on the figures you supply. It is not regulated employment-law advice. Gender pay gap reporting is governed by Equality Act 2010 regulations - for substantive disputes around equal pay or compliance issues, contact ACAS on 0300 123 1100 or use a regulated employment solicitor.