Employees who were paid less than their standard pay due to being on temporary leave should be considered as relevant, but not as full-pay relevant employees, which means that any furloughed employees must be counted when establishing what the employer headcount is, and included in the gender pay gap calculations, when:
• Calculating the percentage of men and women receiving bonus pay • Calculating the average (mean) gender pay gap using bonus pay • Calculating the median gender pay gap using bonus pay
These calculations are made using relevant employees and so should include any employees that were placed on furlough.
Furloughed employees that received less than full pay would not count as full-pay relevant employees, due to the fact that they were paid a reduced rate as a result of being on a period of leave. Employees on furlough who received less than full pay must be excluded from gender pay gap calculations when:
• Calculating the average (mean) gender pay gap using hourly pay • Calculating the median gender pay gap using hourly pay • Calculating the percentage of men and women in each hourly pay quarter
Furloughed employees receiving less than full pay do not count as full-pay relevant employees, as they were paid a reduced rate due to being on a period of leave. You must exclude employees on furlough who received less than full pay in your gender pay gap calculations when:
• Calculating the average (mean) gender pay gap using hourly pay • Calculating the median gender pay gap using hourly pay • Calculating the percentage of men and women in each hourly pay quarter
If employees had their salaries topped up to their normal levels whilst on furlough, then they would also count as full- pay relevant employees for the purposes of calculations. If any employees agreed to defer a portion of their earnings, and were not placed on furlough, they would also be considered as full-pay relevant employees as they were not paid at either a reduced rate or nil as a result of being on leave.
CIPP comment
The Policy team would be interested in hearing from you – please send any comments or feedback you may have on this mandatory reporting requirement, particularly given the current challenging circumstances we find ourselves in, to Policy@cipp.org.uk.
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UK firms to be given six months following the Gender Pay Gap reporting deadline before enforcement action taken 24 February 2021 The media has reported that companies will not be required to publish Gender Pay Gap (GPG) data for a further six months, and it is expected that the Government Equalities Office (GEO) will announce the extension of the deadline shortly. The Equality and Human Rights Commission (EHRC) has urged companies to report by the standard deadline where they are able to. However, they also confirmed that enforcement proceedings would not commence until six months following the standard deadline date.
Both the GEO and the EHRC made the announcement last year that, due to the pressures caused by the outbreak of coronavirus, the enforcement of gender pay gap reporting deadlines was suspended for the reporting year 2019-20.
The Chartered Institute of Payroll Professionals
Payroll: need to know
cipp.org.uk
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