Last updated 2025-10-23
Quick overview
Since 2017, UK employers with 250 or more employees have been required to publish annual reports comparing the average pay of men and women.
The law aims to highlight gender-based disparities and encourage companies to address pay gaps through transparency and accountability.
While there is no legal requirement to take corrective action, regulators can enforce compliance, and non-reporting can result in significant reputational damage.
Equal pay between men and women for the same or equivalent work is a legal right under the Equality Act 2010.
The UK is not required to implement the EU Pay Transparency Directive but continues to strengthen its domestic equal pay framework through reviews and consultations.
Reporting requirements
Which companies must report?
Private and public sector employers with 250 or more employees on the relevant snapshot date must publish an annual gender pay gap report.
The snapshot dates are
31 March each year for most public sector employers
5 April each year for private, voluntary, and other public authority employers
Applicability must be assessed annually.
The obligation applies to anyone working under a contract of service, a contract of apprenticeship, or a contract personally to do work. This includes employees, casual workers, and some contractors.
What information needs to be reported?
Employers must calculate and publish six key metrics showing differences between male and female employees:
Mean gender pay gap in hourly pay
Median gender pay gap in hourly pay
Mean gender pay gap in bonus pay
Median gender pay gap in bonus pay
Proportion of male and female employees receiving bonuses
Proportion of male and female employees in each pay quartile band
No individual salaries are disclosed.
Only percentage differences or ratios are published.
A director or equivalent must sign a written statement confirming the accuracy of the figures.
Employers are encouraged to include a narrative and action plan explaining the results and outlining steps to address any pay gaps, although this is voluntary.
When and where to send the data?
Employers must submit their results to the UK Government Equalities Office via the Gender Pay Gap Service and publish the same information on their own website in a prominent place. Reports must remain accessible online for at least three years.
Deadlines are
30 March for most public authorities
4 April for private and voluntary sector employers
Who can see the results?
Reports are publicly available on both the employer’s website and the government portal.
This enables employees, investors, media, and the public to review and compare gender pay gap data across organizations.
Once published, the data cannot be withdrawn.
Equal pay laws
The Equality Act 2010 makes it unlawful to pay men and women unequally for the same, similar, or equivalent work.
Work is considered equal if it is
like work
work rated as equivalent under a job evaluation scheme
or work of equal value requiring similar skill, effort, and responsibility
Pay differences are only permitted if they are justified by a material factor unrelated to gender, such as seniority, experience, performance, or market conditions.
Equal pay claims can be brought to an employment tribunal during employment or within six months of leaving a job. Successful claims can result in back pay for up to six years and a formal declaration of equal pay rights.
The government has announced plans to create a regulatory and enforcement unit dedicated to equal pay oversight, but no implementation date has been confirmed.
Employee rights
Employees have the right to
receive equal pay for equal work
bring an equal pay claim before an employment tribunal
discuss pay with colleagues or trade union representatives when investigating potential discrimination
access published gender pay gap data for their employer
Any contractual clause that attempts to prevent pay discussions is unenforceable if the disclosure is made to identify possible pay discrimination. Employees are also protected from victimization if they make or seek a relevant pay disclosure.
Risks of non-compliance
Employers that fail to publish gender pay gap data may face investigation by the Equality and Human Rights Commission (EHRC). The EHRC considers non-reporting to be an “unlawful act” under the Equality Act 2010.
The enforcement process usually involves
An initial warning or letter from the EHRC
A formal investigation if the employer does not comply
A potential court order in the event of continued failure
There are no fixed fines written into the legislation, but a court order for non-compliance can result in unlimited financial penalties.
Non-compliance also carries reputational risks that may affect recruitment, retention, investor confidence, and brand trust.
What will change by 2026
New EU-wide rules
The EU Pay Transparency Directive introduces standardized reporting and pay transparency rules across all EU member states by 2026. Although the UK is no longer an EU member and is not required to implement the directive, many multinational organizations will need to comply with it elsewhere in Europe.
Key EU changes include
mandatory salary range disclosure in job ads or before interviews
employee rights to request pay information for comparable roles
mandatory action plans when pay gaps exceed 5%
stronger enforcement and sanctions
How the UK is likely to apply them
The UK is not legally bound by the directive but is monitoring developments closely.
The Equality (Race and Disability) Bill now under consultation may introduce new transparency and reporting obligations that align with or exceed the EU standards.
Current government calls for evidence, open until June 2025, include proposals to
require salary information in job advertisements or before interviews
provide employees with details on pay structures, progression criteria, and relative pay levels
These consultations signal a likely shift toward broader pay transparency obligations after 2025, even without EU membership.
FAQ
Is equal pay already a legal right in the UK?
Yes. The Equality Act 2010 requires equal pay for men and women performing the same or equivalent work.
Who must publish gender pay gap data?
All employers with 250 or more employees on the relevant snapshot date.
Are there penalties for not reporting?
Yes. The Equality and Human Rights Commission can investigate and obtain court orders, which can lead to unlimited fines.
Do employers need to take corrective action if a gap is identified?
Not yet. There is no statutory duty to close gaps, but the government has indicated plans to introduce mandatory action plans in the future.
Are job ads required to include salary ranges?
No current requirement, but this is under review as part of 2025 consultations.
Does the EU Pay Transparency Directive apply in the UK?
No. However, UK employers operating in EU member states must comply with local implementation of the directive.
Helpful resources
Equality and Human Rights Commission – Guidance on Gender Pay Gap Reporting
ACAS – Equal Pay and Gender Pay Gap Resources
UK Government Call for Evidence on Pay Transparency (2025)
Equality Act 2010
