Gender Pay Gap Reporting and Action Planning in the UK

Publishing a gender pay gap is not, by itself, illegal, and having a gap does not necessarily mean an employer is doing anything unlawful — pay gaps have structural causes that go well beyond individual pay decisions. What UK gender pay gap reporting requires is transparency: publishing the numbers so the gap is visible, and, increasingly, showing what is actually being done about it.

What has to be reported, and by whom

Under the Equality Act 2010 (Gender Pay Gap Information) Regulations, UK employers with 250 or more employees must publish gender pay gap figures annually. The required figures are the mean and median gender pay gap, the mean and median bonus gap, the proportion of men and women receiving a bonus, and the proportion of men and women in each of four pay quartiles across the organisation. Private and voluntary sector employers report against a snapshot date of 5 April each year and must publish within twelve months; public sector employers use a 31 March snapshot date on a similar cycle. The figures are published on the government’s gender pay gap reporting service and, typically, on the employer’s own website.

Reading your own numbers

A gender pay gap figure on its own tells you very little about its cause — the diagnostic value comes from looking underneath it. The most common structural driver is seniority distribution: if men are disproportionately represented in senior, higher-paid roles and women disproportionately represented in junior ones, a substantial mean or median gap can exist even where men and women doing the same job at the same level are paid identically. The pay quartile breakdown is the most useful figure for spotting this — a gap concentrated at senior quartiles points toward a progression or promotion issue rather than a pay-setting one.

Part-time working patterns are another common driver. Where part-time roles are disproportionately held by women, and part-time roles cluster in lower-paid bands or attract less bonus opportunity, that shows up as a gap even without any difference in hourly pay for comparable roles. Bonus gaps in particular are worth examining separately from base pay gaps, since bonus schemes tied to full-time presence, long hours, or roles typically held by men can produce a large bonus gap even in an organisation with a small base pay gap.

From reporting to action planning

Reporting numbers has been mandatory since the regulations came into force, but the emphasis is shifting toward what employers do next. New government guidance sets out "equality action plans," under which large employers will be expected to identify and implement concrete actions addressing their gender pay gap, alongside a component addressing menopause support — see our guide to menopause at work for what that support typically involves in practice. These action plans are currently voluntary, alongside standard reporting, from April 2026, with mandatory status expected to follow for large employers in 2027 as part of the wider rollout of the Employment Rights Act 2025, covered in full in our guide to what’s changing for UK employers.

What a credible action plan looks like

A credible plan starts from the same diagnostic step as reading the numbers properly: identifying which structural driver, whether that is seniority distribution, part-time patterns, bonus design, or recruitment pipeline, actually explains the organisation’s specific gap, rather than adopting a generic list of initiatives that would apply to any employer. From there, it sets out specific, trackable actions tied to that diagnosis, with a way to measure whether they are working, for example tracking the proportion of women in senior-quartile roles year over year if that is the identified driver, rather than only re-publishing the same headline gap figure annually.

What separates a credible plan from a token one is usually visible in a few places: whether the actions are specific enough to be checked, such as a stated recruitment or promotion target with a defined timeline, versus vague commitments to "review" or "consider"; whether the plan is revisited and reported against year over year, rather than published once and left untouched; and whether senior leadership visibly owns it, rather than it sitting solely as an HR document. A gap that persists for several consecutive years without a plan addressing its actual structural cause is a strong signal that whatever has been tried so far is not working, and is worth external scrutiny.

Getting ahead of the requirement

Because equality action plans are voluntary now and due to become mandatory for large employers in 2027, organisations that build the habit of proper diagnosis and a genuine action plan now are in a considerably stronger position than those that wait for the requirement to bite. It also tends to produce better outcomes regardless of the regulatory timeline, since a gap driven by a genuine structural issue in progression or part-time pay design does not close on its own. Structured, current CPD on UK employment and equality reporting requirements is one practical way HR and people teams can stay ahead of a fast-moving area — see our CPD courses for options covering this ground.

FAQ

Is having a gender pay gap illegal?

No. Reporting requirements under the Equality Act 2010 (Gender Pay Gap Information) Regulations require transparency about the gap, not a legal cap on its size. A gap can reflect lawful factors such as seniority distribution or working patterns, though a persistent unexplained gap is worth investigating.

Which employers have to report?

UK employers with 250 or more employees, across private, voluntary and public sectors, though the exact snapshot date and reporting deadline differ slightly between the private and voluntary sector and the public sector.

Are equality action plans mandatory yet?

Not as of the current rollout. They are available on a voluntary basis from April 2026 for large employers, alongside standard reporting, with mandatory status expected to follow in 2027. Confirm current status against gov.uk guidance as the date approaches.

What is the difference between the mean and median pay gap?

The mean gap compares the average hourly pay of men and women across the organisation, which can be skewed by a small number of very high earners. The median gap compares the middle value of each group’s pay distribution, which is less affected by outliers and often considered a more representative single figure.