COVID-19: UK Gender Pay Gap Report Filing suspended

25 March 2020

The Gender Pay Gap reporting in the UK has been suspended by the Government. The announcement was made on 24 March to suspend gender pay gap reporting requirements for this year due to the Coronavirus outbreak.

Key Points:

  • Gender pay gap reporting obligations, which look at the difference between the average earnings of men and women, expressed relative to men’s earnings, were introduced in 2017 and apply to businesses and organisations with over 250 employees. However, in light of the COVID-19 pandemic, the government has decided that companies will not be expected to report their gender pay gap data this year.
  • Reporting for this year would have covered data from the 2018-19 “snapshot date”, which is 5 April every year. The deadline for reporting this data would have been 4 April 2020, and so any employers that have not reported already will have their reporting obligation suspended. Over 3000 employers have already completed their gender pay gap reporting  – about a quarter. The government has noted that any companies that are still in a position to report their gender pay gap data can continue to do so and will be provided with support by the Government Equalities Office.
  • Under normal circumstances, the Equality and Human Rights Commission would have the power to investigate any employers that fail to satisfy their gender pay gap reporting obligations, and these employers could face an unlimited fine after court action.

Tapestry Comment
Given the difficulties that many companies are facing in the wake of the COVID-19 outbreak, this decision by the government will be helpful to those companies that have not yet completed their gender pay gap reporting for this year or where they cannot now get into their office to do the filing.

Many companies will have already prepared their Gender Pay Gap Report though and will have been waiting until the end of the month to submit.  It is likely that many of those organisations, especially where they have good data and progress in their gender equality initiatives, will still want to submit or at least publish on their own website. It has been helpful that the Government Equality Office recognises that as offices have been forced to close some will not have access to their reports to be able to submit.  The UK’s Gender Pay Gap reporting requirements have been important in bringing gender equality to the forefront of boardroom discussions and, whether or not a company chooses to submit at a later date, if companies want to make progress on gender equality and show to women in their organisations that it is important, they may want to publish their data when they can.

It is worth noting that, at present, the government decision does not look to have any impact on future gender pay gap reporting obligations and deadlines, meaning that companies will still be expected to submit their gender pay gap reporting data for 2019-20 by April 2021.


If you would like to discuss the impact of COVID-19 on your share plans, please do let us know.

Janet Cooper OBE

Janet Cooper

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