Ensuring you meet your legal obligation to provide equal pay for women and men is not a one-off event. Once you’ve ensured that your pay system is free from bias and that you’re paying people fairly based on the value of the work they do, it’s important to keep it that way.
To do so, you need to continue to review and monitor how your pay system is working in practice. Annual monitoring is recommended, paying particular attention to common problem areas such as:
- starting salaries on entry to the organisation and to grades: take care not to import pay discrimination from elsewhere
- rates of progression: whether men and women are progressing equally, and
- performance-related pay that is clearly linked to a defined level of performance.
It’s also important to introduce and maintain an ongoing review of the impact of any new pay policies as and when they are implemented.
If your organisation is a public body in Wales or Scotland, an equality impact assessment of your policies and practices is likely to be a legal requirement. If you’re a public body in England or your organisation is in the private sector, an equality impact assessment, or equality analysis is an effective way to assess the risk of the proposed changes.
Consider other equality issues that may affect pay gaps
Apart from helping you to meet your legal obligations on equal pay, carrying out an equal pay audit or review can have other beneficial effects. For instance, it could reveal other equality issues in your organisation, such as under-representation or job segregation of people with certain protected characteristics.
If so, you may want to examine other employment practices to ensure they are free from discrimination of all types. These might include recruitment processes, approaches to training and development, and succession planning.
While every effort has been made to ensure that this advice is accurate and up to date, it does not guarantee that you could successfully defend an equal pay claim. Only the courts or tribunals can give authoritative interpretations of the law.
Last updated: 19 Feb 2019