How to Write and Submit a Gender Pay Gap Report: The Complete Guide

Who Needs to Produce a Gender Pay Gap Report?

You are legally required to produce a gender pay gap report if your organisation has 250 or more employees on your snapshot date. This applies to:

• Private sector employers
• Voluntary sector employers
• Public authority employers

The threshold is assessed on the snapshot date each year — 31 March for most public authority employers and 5 April for private, voluntary and all other public authority employers. If you have 250 or more relevant employees on that date, you must report for that year.

The obligation applies to each legal entity separately. If your organisation operates through multiple legal entities, each one with 250 or more employees must report independently.

Employers with fewer than 250 employees are not required to report but may do so voluntarily.

What Must Your Gender Pay Gap Report Include?

Your report must contain six statutory figures. There are no optional extras here — all six are required:

1. The percentage of men and women in each hourly pay quarter — your workforce divided into four equally-sized groups from lowest to highest paid
2. The mean (average) gender pay gap for hourly pay — the difference in average hourly pay between men and women
3. The median gender pay gap for hourly pay — the difference at the midpoint of the male and female pay distributions
4. The percentage of men and women receiving bonus pay — across the 12 months ending on your snapshot date
5. The mean (average) gender pay gap for bonus pay
6. The median gender pay gap for bonus pay

Figures can be reported as whole percentages or rounded to one decimal place.

The Written Confirmation Statement

Your report must be accompanied by a written confirmation statement signed by an appropriate senior person — such as a director, CEO, or equivalent. This statement confirms that the information in your report is accurate and has been calculated in accordance with the regulations.

Without this statement your report is not compliant, even if the figures themselves are correct. It is submitted as part of the online reporting process.

The Narrative Statement — Optional But Important

Alongside your six statutory figures, you can publish an optional written narrative. This is your opportunity to explain the story behind the numbers — why a gap exists, what it is and isn’t telling people, and what your organisation is doing about it.

The narrative is not submitted to the government portal — it sits on your own website. But it can be one of the most valuable parts of your report for several reasons:

• A gap driven by occupational segregation (many women in part-time or lower-paid roles) tells a very different story to one driven by unequal pay for equal work — the figures alone won’t make that distinction
• Employees, candidates, and journalists will read your published figures — a narrative gives you control of the context
• Year-on-year comparison becomes meaningful when you explain the factors driving change (or the lack of it)

What to include in your narrative

There is no prescribed format, but effective narratives typically cover:

• Context for the figures — what is driving your gap (e.g. a high proportion of women in part-time customer-facing roles, or a male-dominated senior leadership team)
• What the gap does and doesn’t mean — the gender pay gap measures the difference in average pay across all men and women in your organisation; it is not the same as unequal pay for equal work
• What you are doing about it — specific actions, not vague commitments
• Progress over time — how your figures have changed year-on-year and why

The Reporting Deadlines

You must submit your gender pay gap report within 12 months of your snapshot date. The specific deadlines are:

Employer Type	Snapshot Date	Reporting Deadline
Most public authority employers	31 March	30 March (following year)
Private, voluntary and all other public authority employers	5 April	4 April (following year)

Don’t leave it to the last minute. Gathering payroll data, calculating six figures correctly, getting senior sign-off, and drafting a narrative all take more time than most HR teams anticipate — especially if this is your first year or if your figures raise internal questions that need to be addressed before publishing.

How to Submit Your Report

Submission is online via the government’s Gender Pay Gap Service at gender-pay-gap.service.gov.uk. The process is:

1. Create an account — or sign in if you’ve reported before. If someone else is submitting on your organisation’s behalf, they need to create their own account and add your organisation to it.
2. Enter your six figures — you can save and return to these before submitting, so you don’t have to do it in one sitting.
3. Submit the confirmation statement — signed off by an appropriate senior person.
4. Publish on your own website — your figures and written statement must also be published on a publicly accessible page of your organisation’s website and remain there for at least three years.

Late submission is visible to the public — the government service marks non-compliant employers with a “late” status, which is publicly searchable. The Equality and Human Rights Commission (EHRC) is responsible for enforcement and can take action against employers who fail to report.

Publishing on Your Website

Your statutory figures and confirmation statement must be published on your own website as well as submitted to the government portal. The information must be:

• Accessible to employees and the public
• Kept on the website for a minimum of three years
• Consistent with the figures submitted to the government service

Your optional narrative can be published on the same page. This is typically a dedicated gender pay gap page, often linked from your careers or ESG/about pages.

Common Mistakes That Catch Employers Out

Confusing the snapshot date with the reporting deadline

The snapshot date (5 April or 31 March) is the date you assess your workforce and take your pay data from. The reporting deadline (4 April or 30 March the following year) is when you must submit. Confusing the two — particularly for first-time reporters — is a surprisingly common source of late submissions.

Wrong figures because the data wasn’t prepared correctly

The most common source of inaccurate reports isn’t errors in the calculations — it’s errors in the underlying data. Using the wrong employee group for bonus calculations, failing to pro-rate bonuses, or incorrectly identifying full-pay relevant employees will all produce wrong figures even if the maths is right.

Forgetting to publish on the company website

Submitting to the government portal is not enough on its own. You must also publish the figures on your own website. Employers who submit but don’t publish are still technically non-compliant.

Not getting the confirmation statement signed

Your report must have a confirmation statement signed by an appropriate senior person. Submitting without it is non-compliant.

Figures that don’t match between the portal and the website

If you publish one set of figures on your website and submit different figures to the portal — even due to a rounding difference — this creates a compliance risk and can attract scrutiny. Always check consistency before going live.

Start With Clean Data

A well-written report starts long before you open the government portal. Getting your employee data right — knowing which employees to include, how to handle bonuses, and how to calculate hourly pay — is where most of the real work happens.

If you want to skip the manual work entirely, the Gender Pay Gap Report Toolkit handles all six statutory calculations in one place. Enter your employee data once — the tool produces every figure you need to submit.

Frequently Asked Questions

What is the deadline for gender pay gap reporting?

30 March for most public authority employers (based on a 31 March snapshot date), and 4 April for private, voluntary and all other public authority employers (based on a 5 April snapshot date). Both deadlines fall within 12 months of the snapshot date.

Do I have to publish a narrative with my gender pay gap report?

No — the narrative is optional under the current regulations. However, it is strongly recommended. Without a narrative, your figures are published without context, leaving employees, candidates, and the media to draw their own conclusions. Under the Employment Rights Act 2025, employers will be required to publish a formal equality action plan alongside their report, with the first mandatory plans expected by April 2028.

How long must gender pay gap data remain on my website?

At least three years. After three years you may remove old reports, though many organisations choose to keep them to show year-on-year progress.

What happens if I don’t submit my gender pay gap report?

Failure to report is unlawful. The Equality and Human Rights Commission (EHRC) can take enforcement action. Late submissions are also publicly flagged on the government service with a “late” status, which is visible to anyone searching the portal — including employees, candidates, journalists, and investors.

Can I submit my gender pay gap report before the deadline?

Yes — and it’s advisable to do so. You can enter and save your figures on the government portal before you’re ready to submit, which allows for internal review and sign-off without time pressure. Early submission also avoids the risk of a late flag if something goes wrong at the last minute.

Does the gender pay gap report cover all employees or just full-time staff?

It covers all relevant employees — full-time, part-time, job-sharers, and those on leave — subject to the specific rules about which employee group applies to which calculation. Part-time employees are included, and because the calculations use hourly pay rather than salary, they are treated comparably with full-time staff.

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