Gender Pay Gap Reporting 2019

concept inequality robots: gender pay gap reporting

It’s that time of year again with the 2019 gender pay gap deadline looming so we thought a brief overview would be valuable. Plus, here are a few of our thoughts on actually tackling the gender pay gap, instead of just talking about it or otherwise hunkering down to avoid the flak!

The Basics:

If you didn’t know already. Beginning April 2018 any organisation with 250 or more employees had to publish and report gender pay gap figures. In plain English, the gender pay gap means the differences between the average earnings of men and women – its not about comparing the salaries of people employed to do the same job.

A few statistics…

  • In 2018 the gender pay gap between full time employees was 8.6%
  • In 2018 the gender pay gap between full time employees aged between 18 and 39 was 0%
  • The gap itself varies between sectors. It is 4.8% in sales and customer services but increases to 23.9% in skilled trades occupations.
  • Only 94% of organisations hit the 4 April deadline last year. In total 10500 reported. The slowest ones to report didn’t get to the finishing line until August.
  • Since 1997 all age groups have seen a narrowing gender pay gap – with the exception of those over 60 yrs
  • The gender pay gap in London has barely changed in the last 20 years.
  • 11000 organisations have to report under this legislation in the UK

For interest: the gap in HR management roles is 12.5%. Women hold 69% of HR jobs. The gap in training roles is 10.3%.

(ONS Office for National Statistics)

The due date for 2019 gender pay reporting is 30th March for public sector organisations and 4th April for the private sector.

What happens if Brexit and all such chaos means you’ve missed the deadline?

Here’s what may happen:

The Equality and Human Rights Commission (EHRC) will initially seek an informal resolution by writing to you drawing your attention to the fact that you have not complied with reporting obligations. Within 14 days you will be required to acknowledge receipt of the letter and confirm that you will comply with the gender pay gap regulations within 42 days for the past reporting year and by the relevant reporting date in the current reporting year.

If you comply with these timescales, no further action will be taken. However, if formal action is required, the EHRC will begin a ‘section 20 investigation’ to establish whether a breach has been committed.

An employer can be required to provide oral or documentary evidence and, as an alternative to the investigation, will be offered the opportunity to enter into a written agreement to comply with their gender pay gap reporting obligations.

A continuing failure to publish gender pay gap figures could result in the issue of an unlawful act notice requiring the employer to prepare an action plan and, if necessary, an application to court for an order, the breach of which can lead to an unlimited fine.

But I’m just a small company with less than 50 employees!

If you are one of the 5.7 million UK’s SMEs with less than 250 employees then you are not required to report on your gender pay. However, there are some benefits to reporting it even if you are not required to, especially if you are focussed on employee engagement, retention, the attraction of great staff etc.

Sharing such information even though you are not legally obligated to do so is a powerful message and might just help you stand out from your competitors!

Gender pay gap root cause – what to do to balance things up

If you are one of the many who knows you have a gender pay gap and that this is not going to just go away here’s a few of our ideas for tackling the problem:


Lack of transparency across all pay and remuneration can mean that gaps occur without anyone being aware of it. Put resources into analysing your remuneration data and ensure that all those who need to be aware, are made aware


Many gender pay gaps occur at the recruitment stage. If women are recruited on less pay than men on average, but then are treated equally thereafter, the gap will just increase year on year as % pay increases are applied to the different amounts. A small gap steadily becomes a bigger gap without any ‘discrimination’ or unequal treatment occurring after the point of entry.

Reasons for Leaving 

Women aren’t always as honest as they could be! Did you know that a lot of women leave organisations claiming they want to spend more time with their family but in fact they are leaving due to not liking their boss or the culture? However, their lack of honesty at the point of departure, done usually to protect their reference and avoid any conflict, means that many managers are not actually aware of why women are leaving resulting in changes never being made.


If you have insufficient women staying with you post junior management roles then its time to look at why exactly they don’t stay with you as if you can’t get women to stay on into the more senior roles you will always have a gender pay gap. Ask, question, probe, reflect, ask again, probe some more. If you won’t like what the reason is it’s likely the answers won’t be very forthcoming so create an environment in which people feel able to be honest so you can find out exactly what you’re dealing with.


There’s no point in sweeping it under the carpet, there are still a fair proportion of men (and other women) who view women as less competent and therefore fewer promotion opportunities are offered to women by these men and lower salary increases are agreed. Whether its conscious bias or unconscious bias, its no one’s fault, as we are all biased. But put some training in so that both men and women become more aware of how biases can impact the gender pay gap and of course, women’s success and satisfaction in the workplace.

See it. Develop it

All too often women don’t go for the bigger jobs. They hold back waiting to be invited or telling themselves they are not quite ready yet or it’s a job that’s just a bit beyond their abilities. If you see some of the women in your organisation doing this, know that its incredibly common and it ultimately impacts gender pay gap. What you need to do is recognise this as an issue and start to address it rather than hope that the next generation coming through will be different.

We’d love to help you with some of this. Our Managing Director Helen Jamieson has worked for so many years on culture, diversity and inclusion, women in leadership etc. and tackling the root cause of issues is the passion of all of us at Jaluch. Why tinker at the edges when the time is perfect for something a bit more radical or challenging? It won’t always feel safe or comfortable but that’s life and it will definitely reap dividends when it comes to retention, the gender pay gap, employee morale and profitability. Get in touch.

An intriguing story …

Google is the world’s most popular search engine and arguably the most recognised brand in the world. Whilst investigating their gender pay gap last year it came to light that in one particular job, it wasn’t the women on the short end of the pay scale stick, it was in fact the men!

The issue related to the company’s Level 4 male Software Engineers. But rather than pursue a 20 year legal claim as many women have had to do in the UK courts when claiming equal pay, you will be pleased to hear that Google, on identifying the problem, promptly paid out an eye watering $9.7 million in compensation to 10,677 employees, the majority of whom were men.

Perhaps part of their desire to resolve the issue was that they had been fined just the previous year by the US Department of Labor for refusing to publish their bonus information. That doesn’t though take away the hint of unequal treatment given that women have battled for decades to be heard when it comes to equal pay, but the minute men are on the receiving end, the issue is promptly addressed.

Recent articles on gender pay gap reporting you might want to read:

  • Sanctions – a guardian article about what happened to those who failed to make the deadline last year.
  • Reporting Errors – a personnel today article about the errors made by employers last year when reporting.
  • Gap grows – a BBC article about how the gap is growing rather than shrinking.
  • Actions to close your gap – government advice on how to close the gender gap.

Jaluch is here to help! Ask us about our HR support, our training, e Learning, our D&I workshops, Docs Wizard (template HR documents), Training Wizard (ready made training material) and last but not least the work we do week on week with staff (employee) representatives training. Contact us!

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