Gender Pay Gap Reporting – Preparing for 2026

November 18, 2025

Welcome to your November Edition of The HR Insight, where we bring you a focused look at current hot topics in your workplace. Providing you with an insight into the latest advice and strategic guidance to help you support your people and protect your business.

Gender Pay Gap Reporting – Preparing for 2026

Gender Pay Gap (GPG) reporting has become a cornerstone of workplace transparency in the UK. For
employers, it’s not just about compliance—it’s about demonstrating fairness, accountability, and commitment to equality. With new requirements on the horizon for 2026, now is the time to prepare.

What is the Gender Pay Gap?

The gender pay gap measures the difference between the average earnings of men and women across an organisation.

– It highlights structural inequalities, such as fewer women in senior roles or higher representation in lower-paid positions.

– It is distinct from equal pay, which is about paying men and women the same for the same work.

Current UK Law

Since 2017, employers with 250+ employees must publish annual gender pay gap data. This includes:

– Mean and median pay gaps

– Mean and median bonus gaps

– Proportion of men and women receiving bonuses

– Distribution of men and women across pay quartiles

Reports must be published on both the government portal and the employer’s own website, remaining accessible for at least three years. Non-compliance can lead to enforcement action by the Equality and Human Rights Commission (EHRC).

What’s Changing in 2026?

The government has confirmed that from 2026:

– Employers with 250+ staff will need to publish Gender Pay Gap Action Plans, setting out steps to address disparities.

– Consultations are underway to extend reporting to ethnicity and disability pay gaps, likely to follow later in 2026.

This marks a shift from transparency alone to accountability and measurable action.

Preparing if Your Company is Growing Towards 250 Employees

If your organisation is approaching the 250 threshold, proactive preparation is key:

–  Start monitoring now: Track pay and bonus data by gender.

– Trial reporting: Run practice calculations to identify gaps early.

– Develop a narrative: Prepare explanations and outline initiatives to address disparities.

– Strengthen systems: Ensure HR and payroll systems can capture accurate demographic and pay data.

– Engage leadership: Brief directors on obligations and reputational impact.

– Draft an action plan: Begin shaping strategies now—future law will require it.

– Communicate internally: Share progress with staff to build trust and transparency.

Unconscious Bias & Inclusive Leadership

Beyond compliance, closing pay gaps requires a cultural shift. Unconscious bias—the subtle assumptions and stereotypes that influence decisions can affect recruitment, promotions, and pay progression.

Employers should invest in training managers to recognise and challenge bias, ensuring fair opportunities for all staff. At the same time, inclusive leadership is vital: leaders who actively listen, value diverse perspectives, and create equitable pathways for progression will drive meaningful change. Embedding these practices now will strengthen your action plans and position your organisation as a genuinely fair and forward-thinking employer.

Practical Steps for Inclusive Leadership

To embed fairness and reduce unconscious bias, managers can take simple, consistent actions:

Pause before decisions: Take a moment to reflect on whether assumptions are influencing recruitment, promotion, or pay choices.

Diversify input: Involve a mix of voices when setting objectives, reviewing performance, or designing policies.

Use structured criteria: Apply clear, consistent frameworks (e.g., competency-based scoring) to reduce subjectivity.

Encourage open dialogue: Create safe spaces for staff to share experiences and feedback without fear of reprisal.

Model inclusivity: Leaders should demonstrate respect, active listening, and recognition of diverse contributions in everyday interactions.

Embedding these practices now will strengthen your Gender Pay Gap action plans and build a culture where all employees feel valued and supported.

Key Takeaways

– Reporting is mandatory for employers with 250+ staff.
– From 2026, action plans will be compulsory.
– Ethnicity and disability pay gap reporting is on the horizon.
– Preparing early ensures smoother compliance and stronger employee confidence.

If your organisation is growing and you anticipate reaching 250 employees, now is the time to prepare. The HR Team can support you with trial reporting, action plan development, and clear communication strategies to ensure compliance and build trust.

Contact The HR Team today for tailored advice and practical support.

 

 

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