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Pay gap reporting

Across the UK, organisations are required to report gender pay gap results annually. These figures can be a trigger for change, but further analysis is critical to understand the full picture of organisational diversity and identify the root causes that drive lasting progress. For many organisations, reporting is the start of a wider review of pay gap data, workforce patterns, and inclusion priorities.
12.8%

UK median gender pay gap, all employees1

30+

Estimated years to close the gap at the current rate of progress2

5

Sets of reporting obligations expected from April 2027 for employers with 250 or more employees3


Calculating a pay gap is just the start

Our multidisciplinary approach (spanning reward, talent management, analytics, and diversity, equity and inclusion) enables organisations to tackle the root causes of their pay gaps.

Our research shows that pay gaps are partly about pay, but largely about the workforce profile. Understanding the wider workforce dynamics is integral to helping leaders address their gaps and work towards a thriving organisation. This is where a gender pay gap service can help employers move from calculation to action.

Diagram showcasing that pay gap reporting is not just about the publicly visible statistics and data, but also about the hidden workforce dynamics in play. For example, pay equity and pay processes; career progression, workforce profile and occupational segregation; harnessing a culture of diversity, equity and inclusion.

Why reporting alone is not enough

  • Since mandatory reporting began in 2017, the overall mean gender pay gap has fallen from 13.4% to 10.7%: fewer than 3 percentage points in nine years4
    At this rate, the ONS estimates it will take over 30 years to close the gender pay gap entirely. The data is a starting point, not a solution.
  • The UK median gender pay gap (all employees) is 12.8%, down from 13.1% in 20245
    The gap is wider for all-employee data because a larger proportion of women work part-time, and part-time roles carry lower median hourly pay. For full-time employees the gap narrows to 6.9%. That is still a meaningful earnings disparity, and one that widens significantly at senior levels. In practice, this means part time employees often shape overall outcomes, even where core pay structures appear consistent.
  • 78% of reporting employers paid men more than women on median hourly pay in 2024/25. Only 9% reported equal pay at the median6
    We need to move beyond compliance to understand how we are tackling the causes of pay gaps across all demographics. That includes looking at average earnings, representation, career progression, and the experience of men and women across the workforce.
  • The pay gap is largest at the top: employees at the 90th percentile face a 15.2% gender pay gap, versus 6.9% at the median5
    Senior pipelines and promotion practices are where the biggest gains can be made, and where Mercer's workforce analytics have the greatest impact. Pay gap reporting can reveal structural inequalities in the workforce, including occupational segregation and uneven progression into senior roles.

Five obligations converging by 2027

UK employers with 250 or more employees face an expanding pay and equality reporting agenda. Gender Pay Gap reporting remains the foundation: it is now layered with ethnicity and disability pay gap reporting, Equality Action Plans, and menopause support, all converging towards a broader equality system.

Under current rules, employers must publish gender pay gap information each year, including median pay, average pay, bonus results, and distributions across quartile pay bands. Reports are legally required for qualifying employers and must include a signed written statement confirming accuracy.

  • Gender Pay Gap (GPG)

    Mandatory · live

    • Mean and median hourly pay gap
    • Mean and median bonus gap
    • % receiving bonus pay
    • Pay quartiles: % in 4 equally-sized groups

    Equality Act 2010 (GPG Information) Regs 2017 · Snapshot: 5 Apr (private) / 31 Mar (public)

  • Ethnicity Pay Gap (EPG)

    Mandatory · expected Apr 2027

    • Same six metrics as GPG
    • ONS harmonised ethnicity classifications
    • Five ethnicities compared where group sizes allow
    • % not declaring ethnicity

    Equality (Race and Disability) Bill: TBC · Same gov portal

  • Disability Pay Gap (DPG)

    Mandatory · expected Apr 2027

    • Same six metrics as GPG
    • Consistent data recording per ONS
    • Employees with and without disability
    • Workforce composition metrics required

    Equality (Race and Disability) Bill: TBC · Single harmonised submission with GPG and EPG

  • Ethnicity Pay Gap (EPG)

    Voluntary · Apr 2026

    Mandatory · 2027

    • Actions to close the gender pay gap
    • Min. 2 actions; new / in progress / embedded
    • Publicly accessible: union and investor scrutiny
    • Will harmonise with race and disability

    Employment Rights Act 2025 · Annual publication on gov website

  • Menopause Action Plans (MAPs)

    Voluntary · Apr 2026  

    Mandatory · 2027

    • At least one action supporting peri-/post-menopause
    • Policies, manager training, occupational health
    • Flexible working and environmental adjustments
    • Discrimination risk under protected characteristics

    Employment Rights Act 2025 · Forms part of the Equality Action Plan

The bigger picture: pay transparency

UK reporting deviates from EU legislation, but many actions suggested by the government for the EAPs reflect an indirect focus on pay transparency.
  • EU Pay Transparency Directive
    UK groups with EU operations (100+ EU employees) must report by 7 June 2027. Drives joint pay assessments where gaps exceed 5% without objective justification. The Directive increases focus on transparent pay data, objective pay criteria, and formal review where gaps exceed 5% without justification.
  • Right-to-pay information
    Candidates gain salary disclosure rights; employers must justify pay differences via objective, gender-neutral criteria, pushing UK firms to align to maintain competitive advantage.
  • From compliance to credibility
    Gaps must be explained or remediated, leading to increasing scrutiny of the story behind the numbers, not just the numbers themselves. Publishing pay gap data can improve transparency and trust, but it can also affect an organisation's reputation if the numbers are not supported by action. 

Key milestones

Now

Gender Pay Gap reporting (live)

Mandatory for all 250+ employers. Annual snapshot: 5 April (private sector) / 31 March (public sector). Six metrics published on the government portal. For private employers, the reporting deadline is 4 April each year, based on a specific date snapshot and the applicable relevant pay period.

Apr 2026

Voluntary Equality Action Plans open

Employers can begin publishing EAPs under the Employment Rights Act 2025. Government guidance (published 4 March 2026) confirms at least one action must address the gender pay gap; at least two must be new or in progress. Plans are publicly accessible and subject to union, investor, and media scrutiny. Although publication begins on a voluntary basis, this creates an early opportunity for employers to strengthen governance and public accountability.

Apr 2027

EAPs, MAPs, EPG, and DPG all become mandatory

Equality Action Plans and Menopause Action Plans become mandatory for all 250+ employers. Ethnicity and disability pay gap reporting is expected on the same timeline (5 April 2027 snapshot date), subject to the Equality (Race and Disability) Bill. A single harmonised submission will cover all three reporting streams. From 2027, action plans will be mandatory for larger organisations, and employers must commit to at least two actions.

Jun 2027

EU Pay Transparency Directive deadline

UK groups with EU operations employing 100 or more EU-based employees must report under the EU Directive. UK employers with European operations should be assessing their position now.


From data to action

Mercer's data-led insights help you understand what you need to do. Our insights are used by organisations across the UK to report their pay gaps, tackle pay inequities, and resolve underlying career inequalities.
  • Data and systems: getting started
    • Implement government-aligned data collection, automate snapshot capture, and track declaration rates across gender, ethnicity, and disability.
    • Provide audit-ready calculations for all six required metrics, pay quartile reporting, and submission-ready outputs for the government portal.
    • Experts in UK, Ireland, and EU legislation enable clients to fulfil their legal requirements with confidence.

    This work often involves validating who counts as relevant employees, how to treat agency workers, and which elements of basic pay should be included when calculating hourly rates.

  • Analytics and benchmarking: understanding the gaps
    • Adjusted pay-equity modelling and intersectional analysis to understand the impact of each pay programme on your gaps and any potential risk areas.
    • Root-cause diagnostics and sector benchmarking to identify where your gaps sit relative to peers.
    • Our internal labour market map highlights the workforce drivers of pay gaps (hires, promotions, and terminations) so you can see which actions will have the biggest impact on diverse representation.

    Understanding an organisation's gender pay gap means going beyond headline figures to assess workforce mix, progression patterns, working hours, and the concentration of female employees in lower-paid roles.

  • Action planning and interventions: closing the gaps
    • Design targeted remediation including pay corrections, career progression frameworks, and reward strategy aligned to identified root causes, with measurable KPIs.
    • Draft integrated Equality Action Plans linking diagnostic findings to specific interventions, ready for the mandatory 2027 requirements.
    • Embed menopause policies, inclusive recruitment, and retention programmes into your broader EAP and inclusion strategy.
    • Job architecture and levelling to address structural drivers of pay gaps across career bands.

    Effective plans also help employers reduce exposure to equal pay claims by improving consistency, decision-making, and documentation.

  • Communications, training, and governance
    • Narrative and disclosure support: craft clear, evidence-based communications for publicly published plans and employee audiences.
    • Manager training and HR/payroll guidance on compliance, methodology, and conducting open conversations.
    • Governance frameworks to establish ownership for reporting, set internal sign-off processes, and ensure calculations follow agreed definitions.
    • Prepare for the formalisation of equality representatives under ERA 2025, which will increase union focus on employers’ equality initiatives.

    Many employers now publish an accompanying narrative and a communications plan to explain results, manage employee expectations, and maintain confidence when reports go live.

FAQs

Reports must include mean and median hourly pay gaps, mean and median bonus gaps, the proportion receiving bonus pay, and pay quartile distributions. This gives a fuller view of pay distribution across a specific company and helps explain differences in job title, level, and workforce profile.

Employers are expected to keep reports on their public website for at least three years. This supports transparency and allows stakeholders to compare progress over time.

Failure to meet reporting requirements can create legal and reputational risk. The UK government and the human rights commission may take interest in persistent non-compliance, and serious failures can lead to enforcement action.

Sources

  1. ONS, April 2025
  2. ONS / mandatory reporting trend, 2025
  3. GPG · EPG · DPG · EAPs · MAPs
  4. ONS / mandatory employer reporting trend data, 2017–2025/26
  5. Office for National Statistics, Gender pay gap in the UK: 2025 (published October 2025)
  6. House of Commons Library, The gender pay gap (updated June 2026)
  7. Mercer, Employer Quick Start Guide: UK Reporting Landscape — Fair Pay and Inclusion (May 2026)
  8. GOV.UK Equality Action Plans factsheet · GOV.UK ethnicity and disability pay gap reporting consultation response (March 2026) · EU Pay Transparency Directive
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