How to prepare and publish your gender pay gap report

Before you start

Legal basis. Section 78 of the Equality Act 2010 and the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 cover private and voluntary sector employers [6][7]. Public authorities listed in Schedule 2 to the Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017 report under those regulations [8]. Public authorities in Scotland and Wales have their own duties [2]. The Equality and Human Rights Commission can take enforcement action for late or inaccurate reports, leading to court orders and fines [2].

Who to involve. Payroll, HR systems, reward, legal, communications and the signatory.

What you need. Everyone employed on the snapshot date, with sex and leave status; pay and hours for the snapshot pay period; and bonus pay for the 12 months ending on the snapshot date.

For how UK employers approach pay gap reporting, see the full findings.

Step 1: Confirm whether you must report, and your dates

Count individuals, not full-time equivalents. Include part-time staff, people on leave, and apprentices, casual and zero-hours staff who are employees on the snapshot date. Self-employed people who must do the work personally also count. Agency workers count in the agency's headcount [2].

Each legal entity with 250 or more employees reports separately. If you reported before and fall below 250, update your reporting requirement on the gender pay gap service, or you will get a "late badge" [2].

Section 34 of the Employment Rights Act 2025, not yet in force, allows regulations requiring employers to name who supplies their contract workers [9]. In the lumi reward benchmark, 7.4% of organisations are prepared to name providers of outsourced workers (n = 230, excluding 36 that answered not applicable).

Step 2: Build your employee list

A relevant employee is anyone employed on the snapshot date. A full-pay relevant employee is one not paid at a reduced rate or nil in the snapshot pay period because of leave: annual, maternity, paternity, adoption, parental, shared parental, sick or special leave [7]. Someone paid less for another reason stays full-pay [3]. Hourly pay measures and pay quarters use full-pay relevant employees. Bonus measures use all relevant employees.

GOV.UK updated its guidance on 21 May 2026, after the Supreme Court's ruling on the meaning of sex in the Equality Act 2010. Record employees by biological sex, including those with a Gender Recognition Certificate, and keep information about a previous gender confidential. Don't single out individuals. If records are unreliable, give employees a proportionate, confidential way to confirm or update them [3].

Step 3: Work out hourly pay

Ordinary pay includes basic pay, allowances, piecework pay, pay for leave and shift premiums. It excludes overtime, redundancy and termination pay, pay for untaken leave, expenses, benefits in kind and interest-free loans. Use gross pay after any salary sacrifice [3].

For each full-pay relevant employee, in the pay period that includes the snapshot date [3][7]:

1. Add ordinary pay and any bonus paid in the period. Prorate a bonus covering a longer period: divide by the days in the bonus period and multiply by the days in the pay period [7]. A £1,200 commission for a 92-day quarter, paid in a 31-day monthly pay period, counts as £1,200 × 31 ÷ 92 = £404.35. Use the actual day counts: the same commission in a 30-day period counts as £391.30.
2. Multiply by 7 divided by the days in the pay period. A month is treated as 30.44 days.
3. Divide by weekly working hours: contractual hours, or for variable hours the average over the 12 weeks ending with the last complete week of the pay period. Exclude hours paid as overtime.

Step 4: Collect bonus pay for the 12 months

Bonus pay is money, vouchers, securities or options relating to profit sharing, productivity, performance, incentive or commission, and long-service awards with a money value. Shares and options count when they give rise to an income tax charge in the 12 months. Include all relevant employees, even those on leave. Bonuses are not adjusted for hours worked [3].

In the lumi reward benchmark, reviewing incentive outcomes by protected characteristic is common: 45.7% of organisations do so, and 30.7% partially (n = 267).

Step 5: Calculate the six measures

The regulations require [4][7]:

1. mean gap in hourly pay;
2. median gap in hourly pay;
3. mean gap in bonus pay, among those receiving one;
4. median gap in bonus pay, among those receiving one;
5. percentage of men and of women receiving a bonus;
6. percentage of men and women in each hourly pay quarter.

Each gap is (men's figure − women's figure) ÷ men's figure × 100. A negative result means men have lower pay or bonuses. Report whole percentages or one decimal place [4].

For quarters, rank full-pay relevant employees by hourly pay and split them into four equal groups. One left over joins the lower quarter; two join the lower and upper middle; three join the lower, lower middle and upper middle. Where people on the same rate straddle a boundary, keep the proportion of men and women at that rate the same in each quarter [4][7].

Step 6: Test your method on a worked example

An invented employer, far below 250. Pay is illustrative. The pay period is a month, with no bonus paid in it.

For M3: £3,300 × 7 ÷ 30.44 = £758.87 a week, ÷ 37.5 = £20.24 an hour.

Results, calculated in Python from unrounded hourly pay:

Quarters: 13 employees, so the lower quarter takes four. Lower: 25.0% men, 75.0% women. Lower middle: 66.7% men, 33.3% women. Upper middle: 33.3% men, 66.7% women. Upper: 66.7% men, 33.3% women. M7 and W8 count only in bonus measures.

Step 7: Write the supporting narrative

A narrative is optional. It can explain what drives your figures and what you are doing [2].

In the lumi reward benchmark, 65.7% of organisations publish no pay gaps voluntarily beyond statutory gender reporting. 18.1% publish an ethnicity pay gap and 12.8% a disability pay gap (n = 265).

Step 8: Get the written statement signed

Private and voluntary sector employers must publish a statement confirming the information is accurate, signed by [7]:

• a company or other body corporate: a director or equivalent;
• an LLP: a designated member;
• a limited partnership: a general partner;
• another partnership: a partner;
• an unincorporated body: a governing body member or senior officer;
• any other body: the most senior employee.

Most public authorities don't need one [2].

Step 9: Submit and publish

Report on the gender pay gap service, with the signatory's name and job title [2][7]. Publish the figures and statement on your website, open to employees and the public, for at least 3 years. Without a website, GOV.UK allows your intranet or parent company's site [2].

Step 10: Link your action plan

For 2026 to 2027, in-scope employers can publish a voluntary action plan on the gender pay gap service, by the same deadlines as the figures. Subject to legislation, plans become mandatory from spring 2027 [5].

Choose at least 2 new or in-progress actions from GOV.UK's list: at least one on your gender pay gap and one supporting employees experiencing menopause. Each needs up to 100 words of supporting text; a 200-word overall narrative is optional. Private and voluntary sector employers name a responsible person, usually a director, partner or senior officer. Each legal entity in scope submits its own plan [5].

In the lumi reward benchmark, 73.7% of organisations publish no equality action plan. 24.8% publish one covering gender and 17.7% one covering menopause (n = 266).

Checklist

• Headcount and deadline confirmed for each legal entity
• Full-pay relevant employees identified
• Sex recorded in line with GOV.UK guidance, confidentially
• Hourly pay calculated for the snapshot pay period
• 12 months of bonus pay collected, including shares
• Six measures calculated and tested
• Narrative decided
• Statement signed by the right person
• Figures submitted and published for 3 years
• Action plan decision made

Related

• Pay gap reporting and action plans: UK benchmark 2026 — the benchmark findings behind the figures in this guide.
• How to calculate and report your ethnicity pay gap
• How to write a gender equality and menopause action plan
• How lumi works: methodology — how these figures are collected and calculated.