Gender Pay Gap Reporting: Summary of updated regulations for 2024

Our advice is to START NOW and get ahead of your autumn/winter workload. Now is the time to start preparing and analysing your 2024 GPG. Unlike other types of organisational reporting, GPG reporting provides a generous lead-in time of six months, which many employers do not take full advantage of. Many delay analysis until October/November and not only risk missing their reporting deadline, but also risk not extracting meaningful outputs, analysis and ultimately, value for the organisation as part of wider Equality, Diversity and Inclusion (EDI) frameworks and Environmental, Social and Governance (ESG) targets.

The true value of GPG reporting

Utilising the time available for a thorough analysis by starting now can provide deeper insights into and understanding of an organization’s GPG data. Those who take full advantage are better able to produce a detailed report with an expanded narrative and summary of the progress made, identifying the key areas where improvements can be tailored to the organisation’s specific needs rather than just meeting the minimum legislative requirements.

While GPG reporting is often perceived as an annual compliance benchmark, its true value lies in supporting broader EDI frameworks. It provides a yearly suite of metrics on the career cycles of male and female employees within an organisation, helping employers identify specific solutions for balancing career cycles, retaining employees, and evaluating the success of practices implemented since the previous year’s report.

A misconception of GPG is that hiring more women will address a pay gap. In reality, hiring is only one part of a wider framework of solutions that includes training, retention, benefits and pay practices, family supports, employee networks and resource groups, amongst others. Employers who establish this link between GPG and wider EDI can identify a more structured and tailored approach to being recognised as a leading equal opportunities employer.

Changes to reporting for 2024

For 2024, the reporting threshold has been reduced to 150 employees (previously 250) and will be further reduced in 2025 to include organisations with 50 employees or more. This year marks the first material change to the reporting threshold since its introduction in 2022. The Government has also revised some reporting regulation elements and has recently released updated GPG reporting guidelines.

• The key changes to the GPG calculation methodology for 2024 are:
• The reporting of pay for those on maternity, paternity, adoptive or parents’ leave.
• Updated working hours calculation
• Update to Benefit in Kind to take account of share options and interests in shares
• Maternity, Paternity, Adoptive and Parents’ Leave

Previously, the regulations were somewhat vague on the inclusion of social welfare benefits in the calculation when an employee on leave was receiving both social welfare benefits as well as a salary top-up from their employer, with only the latter well-defined on its inclusion in the calculation. For 2024, ordinary pay to employees on maternity, paternity, adoptive, or parents leave should consist of the social welfare benefits received by the employee and the salary “top-up” that you are paying for the relevant period of leave. This rewards employers with fully-topped-up pay policies for employees on these types of leave, as employees on leave receiving top-ups equalling 100% of their normal salary should return a comparable hourly rate compared to equivalent colleagues who are not on leave. For those who do not top-up to 100%, affected employees should return a commensurately lower hourly rate aligned with the policy.

Working hours formula

For employers using the weekly hour calculation provided in the regulations, the figure for calculating an employee’s weekly hours has been adjusted to 52.18 weeks from 52.14, likely to reflect 2024 being a leap year. While this change is unlikely to have a material impact on overall GPG figures, it is important that employers use the correct formula to calculate working hours for 2024.

Benefit in Kind

Benefit in Kind (BIK) is any non-cash benefit of monetary value that is provided by the employer. It may also be referred to as notional pay, fringe benefits, or perks, and examples include a company phone, health insurance, etc. The revised legislation has updated the definition of BIK to include share options and interest in shares. Securities other than share options and interest in shares should still be included in bonus payments.

When reporting GPG figures, the monetary value of BIKs is not required and organisations only have to report on the proportion of male and female employees who received BIK. 

How can we help?

Forvis Mazars has been supporting organisations across the public, private and not-for-profit sectors with GPG reporting since 2018, four years prior to the introduction of mandatory reporting. During this time, we have supported our clients through a variety of different solutions, from running GPG calculations on their behalf, validating GPG figures for previous years, providing advice, guidance and training on how to calculate GPG, as well as reviewing and designing practices, activities, frameworks and strategies to address GPG and wider EDI.

Should you require any support, advice or guidance with your GPG calculation for 2024, please do not hesitate to get in touch with a member of the people consulting team.

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