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Gender pay gap reporting: Make a list and check it twice

14 Dec 2022

PwC’s Doone O’Doherty outlines five key actions to consider in preparation for the gender pay gap reporting publication date.

When gender pay gap reporting was introduced in the UK in 2017, the first reports generated significant interest among employees and the media. Overnight, the gender pay gap became a headline story.

Now, gender pay gap reporting is finally upon us in Ireland, with all Irish companies with 250 or more employees required to publish their reports on their websites in December 2022. In preparation, it is important that organisations make a list – and check it twice.

Complete the calculations – specific reporting required

The Gender Pay Gap Information Act 2021 outlines 11 specific data points that must be included in reports. For example, specific reporting is required on pay differences between male and female employees, including hourly pay and bonuses.

Data across a range of working arrangements is also required, including part-time and temporary contracts. Companies should ensure that they understand what is required, that they have gathered all relevant data and that calculations are complete or substantially complete at this stage.

If not already done, the focus should now shift to conducting any additional analysis that may be needed to contextualise the numbers.

Document the approach

The calculations will need to be re-run annually and the 2022 gender pay gap number will be the baseline against which annual progress will be measured.

It is important to ensure that the approach is well documented so that like-for-like can be compared each year. And, as some aspects of the legislation are unclear, judgement may be needed.

In this context, documenting the rationale will be important. This is particularly important if new people are involved in the calculations next year.

Finalise the report – outline measures to be taken

In addition to the reporting of certain data points, the legislation requires that companies explain the reason for the gap and outline the measures taken, or proposed, to close the gap.

Ensure that any reasons for the gap are evidence-based. Do the numbers support the reasons? Also, proposed actions to close the gap will need to be implementable.

In finalising the report, consider whether you need branding support to ensure that the report aligns with other company publications. Who in the organisation will do a final review? With so much detail involved in preparing the analysis, it may be useful to seek a fresh pair of eyes.

Also consider who will provide the final sign-off and who will be responsible for uploading the report to your website. Are they aware of the deadline?

Lock down the communications strategy

With a sensitive, technical topic like gender pay gap reporting, effective communications will be essential.

Ensure that you are prepared to execute your communications strategy.  Confirm that all senior stakeholders are briefed on the key messages for both internal and external audiences.

Consider whether you should nominate a team member as a spokesperson to be responsible for responding to media queries and/or social media comments.

Start to prepare for year two

There will be a very short window between reporting in December 2022 and the next snapshot date in June 2023.

To ensure that you can demonstrate progress in closing your gender pay gap, you must drive ongoing diversity, equity and inclusion (DE&I) plans and consider whether new initiatives are required. Gender pay gap legislation was first initiated in Ireland in April 2019. It was signed into law in July 2021 and we are fast approaching the first reporting deadline.

The steps companies take now when publishing their reports will largely determine how their gender pay gap number will be received and understood, both internally and externally.

By Doone O’Doherty

Doone O’Doherty is a people and organisation partner in PwC.

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