Which employers must report their gender pay gap, and what is changing?
Employers with 250 or more employees on their snapshot date must report and publish gender pay gap data within a year. Action plans on the gender pay gap and menopause support are currently voluntary and are expected to become mandatory in 2027: March for public authorities and April for private and voluntary sector employers.
Who must report and when
Headcount counts individual employees, not full-time equivalents, and each legal entity in a group reports separately. Agency workers count towards the agency's headcount, not the hirer's.
The snapshot date is 31 March for most public authority employers, with a reporting deadline of 30 March the following year. For private, voluntary and all other public authority employers it is 5 April, with a deadline of 4 April. Public authorities in Scotland and Wales have different rules.
What to report
Data is submitted on the gender pay gap service, and the employer also publishes the data and a written statement on its website.
- Mean and median gender pay gap for hourly pay.
- Mean and median gender bonus gap.
- Percentage of men and women receiving bonus pay.
- Percentage of men and women in each hourly pay quarter.
Action plans
Since 6 April 2026, employers with 250 or more employees can publish a voluntary action plan alongside their data on the gender pay gap service. Plans must include at least one action to address the gender pay gap and at least one to support employees experiencing menopause.
The government's timeline expects plans to become mandatory for public authorities in March 2027 and for private and voluntary sector employers in April 2027, in line with the reporting cycles and subject to Parliament.
The law
“an employer who has 250 or more employees on the snapshot date…”
“Regulations may require employers to publish information relating to the pay of employees…”
Sources
- Who needs to report · GOV.UK
- When to report · GOV.UK
- Making your calculations · GOV.UK
- Creating an action plan: guidance for employers · GOV.UK
- Plan to Make Work Pay and Employment Rights Act: timeline update · GOV.UK
General information for employers in Great Britain, not legal advice. Check the official sources for your situation.
- Voluntary gender equality and menopause action plans introduced
- Action plans expected to become mandatory for public authorities (subject to Parliament)
- Action plans expected to become mandatory for private and voluntary sector employers (subject to Parliament)
Future dates are expected dates and depend on Parliament.
What employers can do
- Check headcount for each legal entity on the snapshot date.
- Prepare payroll data, including employees on full-pay leave.
- Calculate the required figures and have them checked; the employer remains responsible for accuracy.
- Submit and publish before the deadline, with a written statement.
- Draft an action plan with at least one pay gap action and one menopause action now, ahead of 2027.
Related answers
- What does equal pay law require of employers? Under the Equality Act 2010, men and women must get equal pay and contractual terms for equal work: like work, work rated as equivalent, or work of equal value. A difference is only allowed where it is genuinely explained by something other than sex, such as location or hard-to-recruit skills.
- What should employers do about menopause at work? Menopause is not itself a protected characteristic, but less favourable treatment because of menopause symptoms can be age, sex, disability or gender reassignment discrimination. Employers should assess workplace risks, consider adjustments and train managers. Employers with 250 or more employees can publish a voluntary menopause action plan now, and this is expected to become mandatory in 2027.
- What is changing under the Employment Rights Act 2025, and when? The Employment Rights Act 2025 is being brought in by phases. Day-one paternity and parental leave, sick pay changes and six-month tribunal time limits already apply. Next come the stronger harassment duties on 30 October 2026, a six-month unfair dismissal qualifying period from 1 January 2027 and fire and rehire protections in March 2027. Future dates remain subject to Parliament.