Government Consultation on Draft Regulations
Government Equalities Office
11 March 2016
We welcome the Government’s intention to introduce regulations on gender pay gap reporting and anticipate that mandatory reporting will encourage large employers to take action to close their gender pay gaps.
We recommend modification of the draft regulations:
- to provide that a contravention of the requirement to publish required pay gap information is enforceable as an unlawful act under Part 1 of the Equality Act 2006
- to make non-compliance with the regulations enforceable only by the Commission
- to require publication of additional measures, including gender pay information for part-time employees and gender pay information relating to starting pay
Alongside the regulations, Government intends to develop guidance for employers that will include strong encouragement to provide a contextual narrative on the causes of any pay gaps. We provide suggestions about issues to be covered in the narrative and guidance.
We also recommend that the Government should undertake to review the operation and impact of the regulations in order to consider whether the reporting requirements should be extended to smaller employers in due course.
Last updated: 03 Jun 2016