The new guidance includes information on who needs to report their gender pay gap, what data must be gathered, how to carry out the relevant calculations, what information must be reported and how to publish gender pay gap reports. However, the gender pay gap reporting requirements themselves have not changed.
A question that many employers will need to consider this year as a result of the pandemic is how furlough affects their gender pay gap reporting obligations. In summary:
- furloughed employees should be included when assessing whether the 250 employee threshold for triggering the gender pay gap reporting regulations is met
- they should also be included in the gender pay gap calculations relating to bonus pay
- however, if the employer did not ‘top-up’ furlough pay, the furloughed employees should not be included in the gender pay gap calculations relating to hourly pay
If gender pay gap calculations are significantly impacted as a result of placing employees on furlough, employers may wish to consider including an explanation for the changes in their narrative.
Links to the new guidance are set out below: