Gender pay gap reporting: UK employment law

Essential points

• In UK law, many employer organisations are required to report their gender pay gap annually. Non-compliance comes with penalties and may have an adverse impact on an employer’s reputation.
• The CIPD defines the gender pay gap as “a measure of labour market or workplace disadvantage, expressed in terms of a comparison between men’s and women’s average (median) hourly rates of pay. It’s about pay, but also about other factors”.
• Specific organisations have additional reporting obligations aimed at ensuring greater pay transparency and progressing equality, particularly those in the public sector, or in industries where governing bodies or regulatory authorities may require this (for example, listed companies and those in the financial services sector).
• Organisations must be aware of further legal requirements operating across Europe and in other countries in which they operate and have staff.  
  The guidance issued below relates to gender pay gap reporting in England, Scotland and Wales.
• When reporting gender pay gap information, employers must use figures which relate to the biological sex of their employees. 
• The Employment Rights Act 2025 will make it compulsory for employers with 250+ employees to develop and publish employer action plans as part of gender pay gap reporting. This requirement is expected to come into force in 2027, with voluntary publication being encouraged from 6 April 2026. The Act also allows for regulations to be made to require that outsourced individuals be included in pay reports. It is expected that these regulations will be made in 2027. Keep up to date with the latest on these changes with our tracker of potential law changes. We will update this page once any changes are in force.