Why Gender Pay Gap Reports Are Due 30 March or 4 April 2027, Depending on Employer Type

Employers in England, Scotland and Wales with 250 or more employees must publish a gender pay gap report every year. Statutory guidance on the government’s gender pay gap service covers reporting, and voluntary action plans can also be published there alongside the pay data. The report compares pay between men and women across an employer’s workforce, and its deadlines are tied to a fixed snapshot date rather than one calendar deadline for every organisation.

Two parts of the framework changed in 2026. In May the statutory guidance was revised so that some references to gender now refer to sex, following a Supreme Court ruling, and the government published guidance on action plans, which say they will become mandatory from spring 2027, subject to legislation. The snapshot dates for the current round passed in March and April 2026, so publication is due by 30 March 2027 for public authorities and by 4 April 2027 for private employers.

Who Has to Report

The threshold is 250 or more employees on the snapshot date. Because the count is taken on that one day, an employer’s headcount then decides whether it must report for the year. According to the Chartered Institute of Payroll Professionals (CIPP), headcount counts individual people rather than full-time equivalents, so a part-time worker counts as one person, the same as a full-time colleague. Certain workers who are not relevant employees are excluded from both the pay calculation and the 250 count. CIPP points to government guidance for the full list of who is included.

Employers with 250 or more employees on their snapshot date must report every year they meet the threshold. Government guidance says each report must be published within a year of that snapshot date.

Snapshot and Deadline
Most public authority employers use a 31 March snapshot and publish by 30 March, while other employers use a 5 April snapshot and private-sector businesses publish by 4 April of the following year, according to CIPP.

Snapshot Dates and Publication Deadlines

Two snapshot dates apply. Most public authority employers use 31 March, and all other employers use 5 April. Private-sector businesses must publish by 4 April of the following year, and public sector employers by 30 March, according to CIPP.

Applying these rules to the round now under way, other employers had a snapshot on 5 April 2026 and private-sector businesses must publish by 4 April 2027. Most public authority employers had a snapshot on 31 March 2026 and public sector employers must publish by 30 March 2027.

On the same annual cycle, the previous round was due by 4 April 2026, with a snapshot on 5 April 2025. Because the two snapshot dates differ, the calendar for most public authorities runs a few days ahead of the one for other employers.

What the Report Contains

The calculations are based on the pay period that includes the snapshot date, according to CIPP. CIPP lists six calculations that must be published: mean and median hourly pay gaps, mean and median bonus gaps, the proportion of men and women receiving bonuses, and the proportion in each pay quartile.

Employers can also add an optional narrative that explains the reasons for any gap and the steps being taken. Reporting was introduced in 2017, according to CIPP.

The report must remain on the employer’s website for a minimum of three years, according to CIPP.

What Changed in the 2026 Guidance

The statutory guidance was revised on 21 May 2026. The section on recording employees’ gender was replaced by a section on recording employees’ sex, which covers what to do when an employee holds a Gender Recognition Certificate. Some references to gender in the chapter on making calculations were also changed to sex.

The change follows the Supreme Court’s ruling in For Women Scotland; HSF Kramer reports that, for the purposes of the Equality Act 2010, ‘sex’ means biological sex. HSF Kramer, a law firm, reports that the revised guidance says reporting must be based on employees’ biological sex. It also reports that the guidance discusses how data can be collected sensitively and confidentially. HSF Kramer says the Government Equalities Office updated the guidance.

Employers with 250 or more employees on their snapshot date must report every year they meet the threshold.

Key Dates in the Reporting Cycle

Reporting was introduced in 2017, according to CIPP. The government’s guidance page was first published on 27 February 2023, and its reporting page was moved into the guidance on 15 March 2023. Guidance on closing the gender pay gap was added on 9 January 2024.

The 2026 dates run in sequence. A banner marking the earlier gender section as under review was added on 27 December 2025. The action plan guidance was first published on 4 March 2026, with step-by-step guidance added on 7 April 2026. The statutory guidance was revised on 21 May 2026, after the King’s Speech on 13 May 2026, which HSF Kramer reports did not include legislation to extend pay gap reporting. Action plans will become mandatory from spring 2027, subject to legislation, and HSF Kramer reads a final impact assessment as pointing to 2029 for ethnicity and disability reporting.

Action Plans and Reporting Ahead

Employers can already publish a voluntary action plan alongside their pay gap data on the gender pay gap service. The government’s collection lists three documents: the statutory guidance, updated on 21 May 2026; the guidance for employers on creating an action plan, dated 13 May 2026; and a list of actions for action plans, dated 4 March 2026. The collection itself was published on 7 April 2026.

The action plan guidance sets out six steps: understanding the issues in the organisation; choosing actions; writing a supporting narrative; submitting the plan; tracking outcomes; and reviewing the plan. Action plans show steps to address the gender pay gap and steps to support employees experiencing menopause. Employers may also describe work already under way to improve gender equality. The guidance was last updated on 13 May 2026 to add information on organisations or groups with more than one legal entity.

According to the collection, action plans will become mandatory from spring 2027, subject to legislation.

Reporting on ethnicity and disability is further away. HSF Kramer reports that legislation to extend pay gap reporting was not included in the King’s Speech on 13 May 2026, and that the extension is less imminent than first expected. It also reads a final impact assessment as pointing to operation in 2029.

For employers, the deadlines in the current cycle are 30 March 2027 for public sector employers and 4 April 2027 for private-sector businesses.

Photo: Wittylama · CC BY-SA 3.0 · via Wikimedia Commons