Gender Pay Gap Reporting 2026/27: An Employer's Guide

What gender pay gap reporting actually requires

Gender pay gap reporting is a legal duty on relevant employers in Great Britain — England, Scotland and Wales — with 250 or more employees counted on a fixed snapshot date. For private and voluntary sector employers, the snapshot date is 5 April each year; public sector employers use 31 March. Whatever headcount an employer has on that single date determines whether they must report for that reporting year, even if headcount later drops below 250.

The duty, introduced under the Equality Act 2010 (Gender Pay Gap Information) Regulations, requires employers to calculate and publish six figures:

1. Mean gender pay gap (hourly pay)
2. Median gender pay gap (hourly pay)
3. Mean bonus gender pay gap
4. Median bonus gender pay gap
5. Proportion of men and women receiving a bonus
6. Proportion of men and women in each of four pay quartiles

Employers publish these figures on their own website (accessible to staff and the public) and on the government's gender pay gap reporting service. The deadline is 4 April the following year — so figures snapshotted on 5 April 2026 must be published no later than 4 April 2027.

Mean vs median: why the same company reports two different gaps

The mean gap adds up the hourly pay of every man, divides by the number of men, does the same for women, and expresses the difference as a percentage of men's average pay. It is sensitive to a small number of very high earners.

The median gap instead lines up all men by hourly pay and picks the middle value, then does the same for women, and compares those two midpoint figures. It is less affected by outliers such as a handful of highly paid executives.

Worked example 1 — a 300-employee retail head office. Suppose the mean hourly pay across 150 men is £19.20 and across 150 women is £16.80. The mean gender pay gap is:

(£19.20 − £16.80) ÷ £19.20 × 100 = 12.5%

Now suppose the median man earns £15.50/hour and the median woman earns £15.10/hour. The median gap is:

(£15.50 − £15.10) ÷ £15.50 × 100 = 2.6%

The large gap between the mean (12.5%) and median (2.6%) figures typically signals that a small group of highly paid men — often senior management — is pulling the average up, while pay for the bulk of the workforce is fairly close. An employee using

can check how a £15.50 versus £15.10 hourly rate translates into actual monthly take-home pay once tax, National Insurance and pension contributions are applied.

Bonus gap and pay quartiles

The bonus gap uses the same mean/median logic but applies it to bonus payments made in the 12 months to the snapshot date, and is reported alongside a separate figure: the percentage of men and the percentage of women who received a bonus at all.

Worked example 2 — bonus gap at a financial services firm. Say the mean bonus paid to men is £4,800 and to women is £3,100:

(£4,800 − £3,100) ÷ £4,800 × 100 = 35.4% mean bonus gap

If 92% of men received a bonus but only 78% of women did, the report must show both figures — the size gap and the participation gap — because a firm could pay men and women similar average bonuses while women are far less likely to be eligible in the first place (for example, if bonus schemes are weighted toward roles or seniority levels held mostly by men).

Pay quartiles split the whole workforce, ranked by hourly pay, into four equal bands.

Worked example 3 — quartiles at a 400-employee logistics company. Each quartile contains 100 employees:

This pattern — more men in the upper quartile, more women in the lower quartile — is the classic driver of a mean/median pay gap even where pay for identical roles is equal. It points to a structural issue: recruitment, promotion or retention patterns that concentrate women in lower-paid roles and part-time positions, rather than one employer paying men and women differently for the same job.

What "ordinary pay" and bonus pay include

Employers must use a specific, defined pay measure, not just whatever figure is convenient. Ordinary pay for the hourly gap calculation includes basic salary, allowances, and pay for leave, but excludes overtime, redundancy payments, and the value of salary sacrifice benefits such as a

. It is converted into an hourly figure using actual normal working hours.

Bonus pay is defined separately and includes cash bonuses, commission, and the cash equivalent of shares, share options or vouchers awarded in the 12-month reference period. Getting these definitions wrong is one of the most common compliance errors — for instance, wrongly including overtime pay in the ordinary pay calculation can distort the mean and median hourly gap figures reported.

Enforcement, deadlines and what happens if an employer doesn't report

The Equality and Human Rights Commission (EHRC) oversees compliance. Employers that fail to report, or that report late, appear as non-compliant on the government's public register. The EHRC can issue an unlawful act notice, which can escalate to a court order and — for continued non-compliance — an unlimited fine, though in practice most enforcement to date has relied on public naming and correspondence rather than court action.

The reporting duty currently applies only in Great Britain; there is no equivalent statutory duty for employers based solely in Northern Ireland. Multi-site UK employers should count Great Britain-based staff against the 250 threshold and are strongly advised to check headcount well before the snapshot date, since headcount can fluctuate close to the 250-employee boundary, especially for employers with seasonal or part-time staff who may also want to check entitlements via

or when auditing payroll data ahead of a snapshot.

What the numbers mean for employees

For an individual employee, a company's published gender pay gap does not reveal what any one person earns — it is an aggregate, workforce-wide figure. What it can indicate is whether an employer has structural imbalances worth asking about at interview or during a pay review: are women underrepresented in senior bands, and is the bonus scheme equally accessible?

The Office for National Statistics has separately tracked a UK-wide gender pay gap for full-time employees that, in recent years, has sat in the high single digits as a percentage, though the exact figure moves year to year and varies significantly by industry, region and age group — it should be treated as a general backdrop rather than a number that applies to any specific employer. Employees curious about how their own pay compares within their profession can use

to see where a given salary sits relative to typical UK earnings, and to check how gross pay differences translate after tax.