Resources · Resources · UK compared
Six numbers in the UK. A system in the EU.
For groups with UK and EU entities: what is the same, what is different, and how to run both reports from one dataset.
UK reporting in brief
- Who: employers with 250 or more relevant employees on the snapshot date, private and public sector.
- Snapshot date: 5 April for private and voluntary sector employers, 31 March for public authorities. Reports are due within 12 months.
- Six figures: mean and median gender pay gap in hourly pay; mean and median bonus gap; the share of men and women receiving a bonus; the share of men and women in each hourly pay quarter.
- Where: on the government reporting service and the employer's own website, with a written statement signed by a senior person confirming accuracy. An explanatory narrative is optional.
- Action plans: voluntary for reports based on the April 2026 snapshot; mandatory for large employers from the April 2027 snapshot, covering the gender pay gap and support for employees experiencing menopause.
- Enforcement: the Equality and Human Rights Commission.
- Sources: Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 (SI 2017/172); Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017 (SI 2017/353); Employment Rights Act 2025.
Lewis Silkin, guidance on equality action plans (March 2026)
Side by side
Art. 3 · EUR-Lex Art. 5 · EUR-Lex Art. 7 · EUR-Lex Art. 9 · EUR-Lex Art. 10 · EUR-Lex Art. 18 · EUR-Lex
| Topic | United Kingdom | EU Directive (EU) 2023/970 |
|---|---|---|
| Reporting threshold | 250 or more employees | 100 or more workers, phased from 2027 to 2031 (Art. 9) |
| Frequency | Annually | Annually from 250 workers; every three years for 100 to 249 |
| Pay basis | Hourly ordinary pay in the snapshot pay period; bonus over 12 months | Gross annual and gross hourly pay for the reporting year (Art. 3) |
| Mean and median gap | Yes | Yes |
| Bonus or variable pay gap | Yes | Yes, complementary or variable components |
| Pay quartiles | Yes | Yes |
| Gap by category of equal work | No | Yes, by category of workers (Art. 9) |
| Trigger for joint action | No | Gap of 5% or more in a category, unjustified and unremedied after six months (Art. 10) |
| Action plan | Mandatory from the April 2027 snapshot | Joint pay assessment with worker representatives where triggered |
| Pay range before interview | No | Yes (Art. 5) |
| Salary history question | Allowed | Banned (Art. 5) |
| Individual pay information | No general right | Right to average pay by sex for equal work (Art. 7) |
| Pay secrecy | Terms preventing pay disclosure for equal pay purposes are unenforceable | Clauses preventing pay disclosure are not allowed (Art. 7) |
| Burden of proof | Shifts once facts suggest discrimination | Shifts; stays with the employer if transparency duties were not met (Art. 18) |
Equal value in the UK
UK equal pay law has long covered like work, work rated as equivalent under a job evaluation study, and work of equal value (Equality Act 2010). Two points matter for job architecture:
- Where an analytical job evaluation study, free of sex discrimination, has rated two jobs differently, a tribunal must find they are not of equal value unless the study is unreliable. A sound evaluation is therefore a defence, not only a compliance tool.
- The employer can justify a difference with a material factor that is not the difference of sex. As in the EU, “we negotiated it that way” rarely survives scrutiny.
- Back pay can reach up to six years in England and Wales and five in Scotland. A tribunal that finds an equal pay breach can order an equal pay audit.
One dataset for both sides
- 01
One job architecture across the group
The same grades make UK equal value analysis and EU categories of workers possible.
- 02
Pay components mapped once
Base pay, allowances, bonuses and benefits in kind, each tagged for the UK and the EU definition. The UK excludes benefits in kind from ordinary pay; the EU counts them as pay.
- 03
Two calculation periods
A snapshot pay period plus a 12-month bonus window for the UK; the full reporting year for the EU.
- 04
Hours defined once
Both regimes need hourly pay; agree contractual hours and how leave is treated.
- 05
Per legal entity
Both regimes report per employer.
Even without a legal duty, many UK groups apply EU standards voluntarily, such as pay ranges in adverts, so candidates and employees see one approach.
Questions
Does the EU Pay Transparency Directive apply in the UK?
No. It applies to employers in EU Member States. A UK group's EU subsidiaries must comply with their national transposition; its UK entities follow UK law.
What do UK employers report?
Six figures: mean and median hourly pay gap, mean and median bonus gap, the share of men and women receiving a bonus, and the share in each pay quarter.
When do UK action plans become mandatory?
For employers with 250 or more employees, from reports based on the April 2027 snapshot date, so the first mandatory plans are published by spring 2028.
Is there a 5% threshold in the UK?
No. The UK has no trigger comparable to the joint pay assessment in Art. 10.
Can UK and EU reports use the same data?
Yes, if pay components, hours and periods are defined so both calculations can be run.
Do UK employers have to publish salary ranges?
Not by law. It is increasingly common practice.