Gender Pay Gap Reporting - Time to prepare
The Department of Children, Equality, Disability, Integration and Youth have published guidance and FAQ documents for employers on how to calculate the various metrics required by the Gender Pay Gap Information Act 2021. While the Act was passed last July, the Regulations setting out more detailed and binding reporting obligations under the Act are expected to be published this week.
In 2022, employers with 250+ relevant employees on the snapshot date in June 2022 (1-30 June - date to be chosen by employer) will have to report on the 12-month period preceding and including the chosen snapshot date on the mirror date in December 2022. This will extend to employers of 150+ employees in 2024 and to employers of 50+ employees in 2025.
What will employers have to report?
As covered in previous Ibec articles, employers will have to report:
- the mean and median gender pay gap
- the mean and median bonus gap
- the mean and median gender pay gap of part-time employees
- the mean and median gender pay gap of temporary employees
- the percentage of male and female employees who received bonuses
- the percentage of male and female employees who received benefits in kind
- the proportion of male and female employees in each of four equally sized quartiles
Employers will be required to include a narrative alongside the figures explaining the reasons the employer believes are relevant for the figures and the actions they have or may take to address the gender pay gap. There is currently no specified format for the gender pay gap information to be published but it must be available on the employer’s website (or an alternative way that is accessible to all employees and the public) for a period of at least 3 years including the reporting date.
The gender pay gap is the difference in the average hourly wage of men and women across a workforce – it compares the pay of all working men and all working women; not just those in same jobs, with the same working patterns or the same competencies, qualifications or experience.
It does not indicate discrimination or bias, or even an absence of equal pay for equal value work – but it does report a gender representation gap – so for example if women hold more of the lower paid jobs in the organisation than men, the gender pay gap is usually bigger.
Guidance on calculations
The Guidance lays out how employers can calculate for each person employed on the chosen snapshot date their total ordinary pay, total bonus, total benefits-in-kind and total hours worked for the reporting period. Employers will also need to be mindful of which employees were full-time, part-time or temporary during the reporting period. All of this will enable their hourly remuneration to be calculated as well as the various calculations required to report the elements above.
It is essential to be aware of the various definitions throughout as they identify what is to be included or indeed excluded from different calculations. This is particularly relevant for employers who may have already reported in other jurisdictions as the definitions may vary e.g., the Irish definition of Ordinary Pay although quite similar to the UK definition, includes overtime and requires employers to have a strong record of all overtime hours to take into account for this calculation.
At this stage there is not a lot of time for employers to undertake this exercise and for many it is a new process which will take time. As such work should begin as soon as possible to prepare the data and calculate the various metrics required. To support that, employers may need a team of key stakeholders from payroll to provide the data, HR to ensure the people data is up to date and to identify or create the initiatives that will help address the gender pay gap, and communications to assist in developing and presenting the report. In addition to the data required it is worth examining additional data around gender balance in recruitment, promotion opportunities, job titles and different levels to understand where possible blocks or opportunities for change may exist.
To support our members Ibec are hosting a briefing on Gender Pay Gap Reporting with Jane Ann Duffy, Principal Officer, Equality and Gender Equality with Department of Children, Disability, Equality, Integration and Youth on June 1st at 11am. This will be a virtual meeting to accommodate as many of those interested in joining as possible.
Given the snapshot date of June 1st-30th and the reporting date of December 1st to 30th this is an opportunity to get further clarity and understanding of the issues facing your organisation as you engage in this reporting process.
Please register to attend the event here.
In addition, and in the interests of trying to get answers to all of the relevant questions, please feel free to send questions in advance to firstname.lastname@example.org or alternatively raise them during the Q&A session at the event.
Dr Kara McGann
Head of Social Policy, Ibec