Gender Pay Gap Reporting - CIPP policy whitepaper

GENDER PAY REPORTING

Conclusions and recommendations

We acknowledge as we conclude this report that the first reporting year is yet to end and many lessons are still being learned and indeed much knowledge and learning continues on the subject of gender pay gap reporting and so in the coming months and years much will change as we see large employers respond to yet another mandatory obligation that looks to the payroll profession to be the source of data that will enable ‘accurate and timely’ reporting.

And so to attempt to conclude on such a moving beast is almost impossible but we close with a summary of our thoughts and recommendations for the future – as viewed through the lens of the payroll industry.

l We need to see the Government Equalities Office together with Equality and Human Rights Commission reclaim the headlines - Confusion remains around the difference between equal pay and gender pay gaps. This is not helped by the media sensationalising their headlines. Good guidance and information that supports all stakeholders in understanding how to comply and how to understand the implications of each together with the benefits to be gained from gender pay gap reporting as it drives greater inclusion and diversity, which will begin with the larger employer but as we have seen with good examples, the ripple impact on other employers – regardless of size – as they acknowledge that ‘it just makes good business sense to do so’. Opinions have diverged on the wider impacts of the reporting requirement. ‘Understanding what the report means is not straightforward,’ and ‘I have some concerns over the interpretation of the data as some people may try to use it to prove a point, but longer term, more openness and transparency can only be a good thing.’ l Policing of the first year of reports i.e. with the snapshot dates of 5 April 2017 and 31 March 2017, focusses a greater educational and informal approach for all but the least compliant - we repeat our request made in our formal response to the EHRC enforcement consultation. Much can be learned from other Regulators who have the mantle of education and enforcement and much can be gleaned from the largely successful rollout of Automatic Enrolment as a result of the full education portfolio delivered by The Pensions Regulator.

Enforcement by the EHRC was always a concern to payroll professionals who are accustomed to each piece of pay relevant legislation being delivered with a compliance regime clearly mapped out.

We are aware that within five years of commencement, the Secretary of State will review these regulations and publish a report on whether they meet policy objectives or impose an unnecessary burden on employers. and we look forward to being involved with that review.

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