Written by
Ruth Thomas
Senior Consultant and Co-Founder, CURO

18 December 2019

Before we all switch off for the festive period, let’s not forget that there are just over 100 days until the Gender Pay Gap Reporting deadline for 2019/20. The reporting deadline falls under the UK’s Equality Act 2010 (Gender Pay Gap Information) Regulations 2017.

Who is required to report on Gender Pay Gap metrics?

The reporting deadline applies to organisations with 250 or more employees.

Your statutory metrics need to be uploaded to the government's Gender Pay Gap portal by April 4, 2020. For relevant public sector organisations, the deadline is March 30, 2020.

The state of employer reporting so far

So far, only 5% of employers have uploaded their metrics for the 2019/20 period. I’d like to be optimistic and say that many employers have calculated their numbers and are just waiting to publish them ‘en masse’ before the deadline - a tactic used by some to avoid any PR disasters.

In reality many will be leaving it to the last minute to report again. We know that over 20% of companies reported in the last week before the 2018/19 deadline.

Why you shouldn't submit your metrics at the last minute

The biggest issue with late reporting is it gives you no time to put in place actions to address issues causing pay gaps before the next year’s reporting snapshot (April 5th for private companies and March 31st for the public sectors.) Therefore you are unlikely to see any improvement in your numbers year-over-year.

In fact, 51% of employers saw an increase in their median hourly pay gap last year.  With three years of reporting in the public domain, the focus from stakeholders (including your current and future employees) will no doubt turn to why you are not making demonstrable progress.

Late reporting also means you can't drill down into your metrics and unravel some of the flaws with the current reporting regime.  For example, looking at your figures with and without bonus pay included in the ordinary pay calculation to identify any skewing impact of bonus inclusion. Or doing your analysis pre and post salary sacrifice. Deductions for salary sacrifice arrangements are excluded from an employee’s base pay for the purposes of gender pay gap reporting, but this can impact your final gender pay gap data depending on how many women compared to men have taken up a benefit via a salary sacrifice arrangement, by creating an artificially lower rate of pay for those who opt to use salary sacrifice compared to those who do not.

We also recommend calculating a number of other pay and non-pay related metrics to help you diagnose your pay gap and identify where in your talent pipeline issues may be occurring that can drive pay gaps.

Pay Related Metrics

Non-Pay Related Metrics

Comparison of new hire salaries

Applicants vs successful applicants

Comparison of new promote salaries

New hires by job level

Comparison of salary & bonus allocation in review

Tenure in job grade

Off cycle awards by gender

Turnover by job gender and job level

Audit of pay equity amongst highest paid employees

Take up of part time work by gender

Number of incentive/LTI eligible employees by gender

Allocation of performance ratings (or other talent ratings)

Pay increases of women on maternity absence Vs. those not

Understand your gender profiles by role


How to get your reporting done early and make year-over-year improvements

Make sure you’ve allocated time in your diaries for early January to get your reporting done. We know that consistent reporting year-over -year is a challenge which can impact your ability to provide a compelling narrative and demonstrate real progress.

Let us help you this reporting deadline.

CuroGPG is a complete solution for UK gender pay gap compliance, insights and forecasts. Our simple self-service solution helps support companies who need to comply with the Gender Pay Gap Information Regulations and wish to understand the issues driving their Pay Gap.

Contact us to learn more.