Deadline for gender pay gap reporting approaches

06 January 2023

Employers with 250 or more relevant employees have just over 2 months remaining to publish details of their employees’ gender pay gap.

Relevant employees are all those employed by your organisation on your snapshot date. This includes employees who have a contract of employment and those who are self-employed (where they personally perform the work).

Gender pay gap figures compare the average pay of an organisation’s female employees with the average pay of their male employees. A gender pay gap is different to unequal pay. Unequal pay is when an organisation pays men and women differently for carrying out equal work.

Compared to men, women are less likely to work full-time, to progress in their careers and are more likely to be employed in lower-paid occupations. As a result, gender pay gaps continue to be seen and are a key indicator of women’s labour market inequality. In their 2022 Global Gender Gap Report, the World Economic Forum estimated that it will take 132 years to reach full pay parity between females and males.

If applied properly, pay gap reporting has great potential to help the growth and development of an organisation. It is a useful tool, providing data to track how the organisation is progressing over time. The results of the report can help employers to understand more about their own workforce composition, explore why disparities exist and, most importantly, implement organisational change and improvement.

What are the timescales?

For private and voluntary sector organisations, a snapshot of employees’ pay should have been taken on 5 April each year. Pay gap reports must be published on the employer’s own website and uploaded to the government’s website no later than 4 April the following year.

For public sector bodies, the snapshot must be taken on 31 March each year and reports must be published and uploaded by 30 March the next year.

The data must remain on the employer’s website for three years.

6 late reporting risks

Last-minute or late reporting can cause a range of issues including the following.

  1. A greater risk of mistakes when you are rushing your calculations.
  2. Reduced time for data analysis and therefore less time to reflect on future improvement measures or the success of the measures you have previously implemented.
  3. Failure to report and publish your gender pay gap information within one year of your snapshot date is unlawful. The Equality and Human Rights Commission has the power to enforce any compliance failure which could lead to court orders and fines.
  4. A reputational risk if you fail to report and publish your gender pay gap information on time. Not reporting at all can be as damaging reputationally as reporting an unfavourable pay gap.
  5. The gender pay gap service applies a publicly visible ‘late’ badge to registered employers who fail to report and publish their gender pay gap information for any year they are required to do so.
  6. Employees are increasingly looking for employers with a commitment to equality and diversity. With recruitment continuing to be challenging, timely reporting demonstrates to would-be employees that you understand the importance of pay parity.

How can RSM help?

RSM’s People Advisory Services team can help organisations fulfil this important regulatory requirement. For clients who wish to take meaningful action to address their gender pay gap, we can help you go beyond statutory compliance.

Our services include:

Calculations and narrative

RSM will work with you to collate your data on the required snapshot date to:

  • provide the calculations to support your results and to demonstrate accuracy of data;
  • support the drafting of the voluntary narrative; and
  • ensure you receive an annual reminder in the future.


RSM can review and analyse your results to create supporting action plans which may include:

  • a review of current remuneration schemes across your organisation;
  • identify the areas of risk and exposure; and
  • formulate a communications plan.

For those clients who wish to delve even deeper into their pay gap data and gain a wider perspective, RSM can also provide support with running their ethnicity pay gap calculations.

Should you require support or guidance to meet your pay gap reporting obligations, please contact Steve Sweetlove.