Key Points
- With nine weeks remaining, just over one in eight employers have published their 2025/26 gender pay gap data.
- As at 30 January 2026, just 12.98% of in-scope employers had reported, leaving more than 85% yet to comply.
- Late reporting is consistent with previous years, with the majority of employers typically submitting close to the deadline.
- Failure to report on time can result in enforcement action by the Equality and Human Rights Commission (EHRC).
- Although enforcement activity has fallen significantly since 2018/19, non-compliance increased slightly in 2024/25.
- Recent gender pay gap data shows continued narrowing of hourly pay gaps, but bonus pay disparities remain volatile.
With just nine weeks remaining for employers to publish their 2025/26 gender pay gap data, just over one in eight employers have reported so far.
Gender Pay Gap Reporting Deadlines
The statutory deadlines for publishing gender pay gap data are approaching:
- Public sector employers must report by 30 March 2026, using a snapshot date of 31 March 2025.
- Private sector employers and voluntary organisations must report by 4 April 2026, using a snapshot date of 5 April 2025.
Just 12.98% Have Reported So Far
Of the approximately 11,250 employers required to publish gender pay gap data, only 1,460 employers had done so as at 30 January 2026. This represents 12.98% of all in-scope employers.
As a result, with fewer than nine weeks remaining until the reporting deadlines, more than 85% of employers have yet to publish their data, leaving compliance to a very late stage in the reporting cycle.
That said, late reporting is not unusual. In the 2018/19 reporting year, only 1,251 employers had reported by 24 February 2019. Similarly, as at 15 January 2025, just 1,312 employers had submitted their data for the 2024/25 reporting year.
Enforcement Action for Non-Compliance
Employers that fail to submit their gender pay gap data on time risk enforcement action. In the private sector, enforcement is carried out under section 20 of the Equality Act 2006.
Where an employer fails to comply, the Equality and Human Rights Commission (EHRC) may issue an unlawful act notice. If the employer does not comply with that notice, the EHRC can apply to the courts for an order compelling compliance. Breach of a court order may result in prosecution and, on conviction, an unlimited fine.
“Named and Shamed” by the EHRC
Where an employer fails to comply with its reporting obligations and an investigation reaches a formal stage, the Equality and Human Rights Commission (EHRC) publishes details of the employer on its website. A final report is also published at the conclusion of each investigation.
The use of this power has declined markedly since the early years of enforcement. In the 2018/19 reporting year, 47 employers were publicly identified. This figure fell significantly in subsequent years, with 28 employers named in 2021/22 and eight in 2022/23.
Non-Compliance: A Slight Recent Increase
The 2023/24 reporting year saw further improvement, with just six employers named and shamed, reinforcing the trend towards higher overall compliance. However, this downward trajectory was not sustained in 2024/25, when the number increased to 10 employers, indicating a modest uptick in non-compliance compared with the previous year.
What Last Year’s Data Showed
Analysis of the 2024/25 gender pay gap data by PwC indicates continued progress in narrowing hourly pay disparities between men and women, alongside more mixed results in relation to bonus pay.
The mean gender pay gap fell from 11.8% in 2023/24 to 11.2% in 2024/25, a reduction of 0.6 percentage points. The median hourly pay gap also narrowed, decreasing from 9.1% to 8.6%.
The scale of this reduction represents one of the most notable year-on-year improvements since the early years of mandatory reporting, and may reflect a more sustained focus by organisations on workforce composition, pay structures, and progression pathways.
Bonus pay data, however, remains more volatile. While the mean bonus pay gap fell slightly from 29.6% to 29.3%, the median bonus pay gap increased from 14.4% to 15%. This divergence reflects the performance-related and variable nature of bonus schemes, which tend to fluctuate more sharply than hourly pay measures.
Analysis of the gender pay gap data published by the House of Commons Library found that overall, around 78% of reporting employers stated that median hourly pay was higher for men than women, with only 14% reporting higher pay for women and 9% reporting parity.
Employers: What This Means
- Confirm your snapshot date population and headcount early (31 March 2025 for public sector; 5 April 2025 for private/voluntary), including treatment of relevant workers.
- Build in time for data cleansing and methodology checks (hourly pay, bonus pay, quartiles), as errors can create compliance and reputational risk once published.
- Plan internal governance: secure senior sign-off and prepare consistent messaging, particularly where the median/mean gaps or bonus gaps are likely to attract scrutiny.
- Draft a short narrative and action plan that explains key drivers (e.g. pay quartile representation, recruitment/retention patterns) and sets out credible steps to address them.
- Publish on time on the government gender pay gap reporting service and retain a clear audit trail of calculations and source data in case of challenge.
- Consider related risk areas (including equal pay complaints and discrimination claims) where large gaps persist or where there are known pay anomalies.
