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1、1PwC|Mandatory UK Gender Pay Gap ReportingMandatory UK Gender Pay Gap ReportingUnderstanding diversity beyond gender in an evolving reporting landscapeYear 7 UK Gender Pay Gap Reporting 2023/24June 20242PwC|Mandatory UK Gender Pay Gap ReportingForewordAs we reflect on the seventh year of UK gender p

2、ay gap reporting,our analysis shows a decrease in the median of reported mean hourly pay gaps,from 12.2%in 2022/23 to 11.8%in 2023/24.Whilst it is encouraging to see the pay gap reducing each year,the rate of change remains modest.Our analysis suggests that gender pay parity remains out of sight and

3、 it is unlikely that a 21 year old entering the workforce today would see gender pay parity in their working lifetime.At the same time,the global Environmental,Social and Governance(ESG)reporting landscape is evolving rapidly.As part of social reporting,many organisations are increasing their focus

4、on pay fairness and transparency,as well as pay gap and diversity reporting(including beyond gender).In this context,it is now more important than ever for organisations to take a step back to fully understand the state of pay fairness and Diversity,Equity and Inclusion(DE&I)within their workforce.B

5、y truly understanding any DE&I barriers that exist within the workforce and embracing pay transparency,organisations can navigate the reporting landscape and use it as a way to shape their narrative,as opposed to letting it dictate it.10,408Companies disclosed their gender pay gap1.6%Reduction in th

6、e mean pay gap since 201711.8%Median of reported mean pay gapsKey gender pay trends in 2023/242PwC|Mandatory UK Gender Pay Gap Reporting3PwC|Mandatory UK Gender Pay Gap ReportingIntroductionThe gender pay gap has become a widely recognised measure of pay and gender representation within the UK since

7、 the introduction of mandatory reporting in 2017.As a result,many organisations use the metric as one way to monitor and report progress on gender diversity.For 2023/24,our gender pay analysis shows a decrease of 0.4%in the mean hourly pay gap,from 12.2%in 2022/23 to 11.8%,and a median pay gap decre

8、ase from 9.2%to 9.1%.Promisingly,nearly 60%of organisations reported that their pay gap had decreased compared with 2022/23.However,the majority of these reductions were relatively small (that is,between 0%and 2%).Despite some progress,our year-on-year data shows an overall slow pace of change,sugge

9、sting it will take over 45 years to close the gender pay gap in the UK.The gender pay gap itself can often be a lagging indicator,with positive actions to improve gender representation taking years to significantly impact these figures.Acknowledging the external societal influences and systemic barr

10、iers,change remains challenging.However,in order to make meaningful and sustainable reductions to pay gaps,it is critical for organisations to truly understand gender pay gap drivers and take targeted actions to address them.While the pace of change in the reporting figures is slow,the level of exte

11、rnal scrutiny and stakeholder pressure is increasing rapidly.This is being further fuelled by the evolving reporting landscape with growing reporting in areas including:In this increasingly complex landscape,organisations are finding that a simple report on their pay gaps is insufficient to meet sha

12、reholder expectations.Instead,leading organisations are delving deeper to understand the drivers of pay gaps and broader DE&I barriers and the actions that are needed to overcome them.In this way organisations can use the potential of reporting to develop their own narrative,turning compliance into

13、an opportunity for meaningful change.ESG and Sustainability Reporting (such as the EU Corporate Sustainability Reporting Directive).Pay transparency and fairness(the EU Pay Transparency Directive and growing local territory requirements on pay gap reporting).Reporting on diversity beyond gender (eth

14、nicity pay gap reporting).4PwC|Mandatory UK Gender Pay Gap ReportingKey trendsOur analysis shows a decrease of 0.4%in the mean pay gap from 12.2%in 2022/23 to 11.8%in 2023/24.The median hourly pay gap has decreased marginally from 9.2%in 2022/23 to 9.1%in 2023/24.Mean pay gap Median pay gap5PwC|Mand

15、atory UK Gender Pay Gap ReportingMean bonus gapMedian bonus gapThere have been larger decreases to both the mean and median bonus gaps over the reporting period,with the mean bonus gap decreasing by 2.1%from 31.7%in 2022/23 to 29.6%in 2023/24,and the median bonus gap decreasing by 1.3%from 15.6%in 2

16、022/23 to 14.4%in 2023/24.Typically,bonus pay gaps can be more volatile than pay gaps,due to the performance related nature of most bonuses.6PwC|Mandatory UK Gender Pay Gap ReportingSize of change in mean pay gap from 2022/23 to 2023/24When looking at the distribution of changes in the mean hourly p

17、ay gaps for companies that reported in both 2022/23 and 2023/24,58.4%of organisations reported decreases to their mean pay gap.Of this,the majority reported small decreases between 0%and 2%.This is a slight increase in comparison to 2022/23,where 53.7%of organisations reported decreases to their mea

18、n pay gap.Overall,20.1%of organisations reported no change or an increase between 0%and 2%to their pay gap,compared with 17.6%in 2022/23.Proportion of companies vs.change in mean pay gapDecreased mean pay gapIncreased mean pay gap7PwC|Mandatory UK Gender Pay Gap ReportingSize of change in mean pay g

19、aps by organisation size since 2017/18The largest organisations(with 20,000 employees or more)have generally had the lowest mean hourly pay gaps each year,compared to other sized organisations.The smallest organisations display higher levels of volatility in the mean pay gaps,as a single employee ca

20、n have a more significant impact on overall average pay due to the smaller overall employee population.In 2023/24,we can see the mean pay gap has decreased for organisations of all sizes,excluding the largest,which have marginally increased by 0.1%.Mean pay gaps for different sized organisationsNumb

21、er of EmployeesLess than 2501,000 to 4999250 to 4995,000 to 19,999500 to 99920,000 or more8PwC|Mandatory UK Gender Pay Gap ReportingSector trendsOur analysis shows the Financial Services sector continues to report the biggest gender pay gaps.This is reflective of the ongoing issues with gender equal

22、ity within the sector,where potential regulations on diversity and inclusion may be introduced by the Financial Conduct Authority and Prudential Regulation Authority later this year and as outlined in the Treasury Select Committees report on their inquiry into “Sexism in the City”,published in March

23、 2024.Whilst the Financial Services sector has consistently reported the highest pay gaps,they have also reported the biggest decreases in pay gaps compared to the previous year,alongside the Travel and Technology sectors.As with 2022/23,Public Administration,Health,Hospitality and Leisure continue

24、to be the sectors with the lowest mean hourly pay gaps.Mean hourly pay gap as at 5 April 2023/24Changes in mean pay gap by sectorChange in mean hourly pay gap between 2022/23 and 2023/249PwC|Mandatory UK Gender Pay Gap ReportingHow we use analytics to gain an understanding of gender pay gap driversI

25、n order to make meaningful change to gender pay gaps,it is crucial to understand the main drivers of the pay gap and the appropriate actions needed.The demonstrative video below showcases our PwC Diversity,Equity and Inclusion Toolkit that we use to help organisations understand pay gap drivers and

26、movements in reported gender pay gaps.The type of analytics shown can help in understanding where barriers exist and where actions need to be focussed as to sustainably reduce pay gaps.10PwC|Mandatory UK Gender Pay Gap ReportingThe changing reporting landscapeDE&I reporting is quickly evolving withi

27、n a global landscape,looking beyond gender and at broader diversity lenses.UK gender pay gap reporting is now one facet amongst many other diversity lenses and reporting requirements.Please see the appendix for an overview of the reporting frameworks and requirements outlined above.It is important t

28、hat organisations do not let this evolving landscape become a compliance exercise.Instead,reporting and transparency should be embraced,and organisations should focus on implementing actions that will drive meaningful change.Gender specificUK gender pay gap reportingFCA listing rules on diversity re

29、presentation on boards and ExCoInternational sustainability reporting frameworks(CSRD,ISSB and SEC)EU pay transparency directiveThe FTSE women leaders reviewInvestor guidanceVoluntary global sustainability disclosuresUK ethnicity and disability pay gap reportingThe Parker ReviewDE&I reporting standa

30、rds/best practice frameworksIncluding broader diversityUKGlobalFCA and PRA diversity and inclusion regulationMandatoryVoluntarySector specificAnticipatedKey11PwC|Mandatory UK Gender Pay Gap ReportingPwC DE&I reporting checklist:How to drive meaningful changeConduct a thorough compliance exercise to

31、understand which reporting requirements apply to you.Gain a thorough understanding of the DE&I barriers driving pay gaps and reporting metrics by conducting or outsourcing data analytics.Ensure you have collected the right diversity data to meet these requirements.Identify key interventions and focu

32、s areas looking ahead based on this understanding.Ensure you have sufficient diversity data response rates to gain meaningful insights(for voluntary diversity data like ethnicity,disability,socio-economic background,sexual orientation etc.)Ensure an understanding of how these key interventions will

33、impact pay gaps and reporting metrics in the future.Calculate reporting metrics in line with the relevant requirements.Communicate this story and focused actions alongside any reported requirements,ensuring consistency and a clear DE&I focus in the narrative.8765432As we enter the eighth year of man

34、datory UK gender pay gap reporting,the global DE&I regulatory landscape continues to evolve.Organisations must take the chance to lead the conversation on pay fairness and transparency,shaping a future where equality is not a goal,but a reality.12PwC|Mandatory UK Gender Pay Gap ReportingTopic spotli

35、ghtUK mandatory ethnicity pay gap reportingThe topic of ethnicity and other types of pay gap reporting,such as disability,has increasingly become a focus point of discussion within the UK with government consultations,public petitions and parliamentary debates Increasingly,organisations have been vo

36、luntarily calculating and reporting their ethnicity pay gaps(along with other diversity pay gaps such as disability,socio-economic background,sexual orientation etc.),as a key aspect of commitment to DE&I within the workplace.These voluntary disclosures not only showcase transparency,but a shift in

37、the UK market as more companies look in more detail at diversity more broadly and beyond gender.The UK Government consulted on proposals for mandatory ethnicity pay gap reporting.As a result of the petition,Parliament debated ethnicity pay gap reporting.A petition demanding mandatory ethnicity pay g

38、ap reporting received over 130,000 signatures.Timeline of Ethnicity Pay Gap Reporting in the UK:1.For example,PwCs Diversity Pay Gaps Webpage shows PwCs pay gap disclosures which include gender,ethnicity,disability,socio-economic background and sexual orientation.Now,202420182020202120222023The UK G

39、overnment published official guidance for organisations on how to calculate and voluntarily report ethnicity pay gaps.The UK Government confirmed it would not legislate mandatory ethnicity pay gap reporting but expressed support for voluntary disclosures by employers.Mandatory ethnicity and disabili

40、ty pay gap reporting is uncertain until the outcome of the next general election.12PwC|Mandatory UK Gender Pay Gap Reporting13PwC|Mandatory UK Gender Pay Gap ReportingCollecting the right diversity data and ensuring sufficient diversity data response ratesCollecting diversity data is complex,with a

41、number of challenges and legal requirements.If you do not already collect ethnicity data:If you already collect ethnicity data:You will need to consider if there are any employment law and data privacy requirements and ensure appropriate processes are followed(such as the publication of data privacy

42、 notices).We note that this is an area where law may differ significantly by territory,if you will be collecting ethnicity data more broadly than in the UK.You may want to assess the quantity of data collected to ensure your disclosure rates are sufficient for reporting ethnicity pay gaps and for an

43、alysis.We recommend aiming for disclosure rates of 80%or higher,but insights can be gained with at least 60%.It will be important to understand the appropriate questions and attributes for collecting ethnicity data,particularly if you wish to collect ethnicity data in other territories as ethnic gro

44、ups and approaches may significantly vary.If you have an HR system then this may need updating so that ethnicity data can be collected and stored,this could include incorporating certain security measures.You can consider the quality of data collected by analysing how many employees select prefer no

45、t to say.If this number is high then you may want to work on your engagement strategy to build trust with your employees.You may want to ensure appropriate planning of a communications and engagement strategy to encourage high response rates from your employees.Calculating ethnicity pay gaps and und

46、erstanding the DE&I barriers driving these pay gapsCalculating ethnicity pay gaps can be particularly complex as assumptions need to be made on how to classify ethnicities,which pay gaps to calculate and how to interpret the data accurately.You can find Government guidance on ethnicity pay reporting

47、 here,which provides useful information on how to do this.Following this,you will also need to understand the key drivers of any ethnicity pay gaps,including pay gaps for each ethnic minority group.More advanced data analytics may be required,particularly to ensure an understanding of how gender and

48、 ethnicity intersect.This will help to identify key focus areas and targeted interventions from a broader diversity perspective,how these would impact pay gaps over the long-term and how these can be incorporated and communicated as part of a consistent DE&I narrative.PwCs Diversity Data Collection

49、Tool Our approach to collecting diversity dataDetermine scope and objectivesSystems selection,design and enablementLegal and cultural permissibilityCommunications and engagementDetailed legal and privacy analysisEmbedding data collection in the long-termHow can organisations prepare for ethnicity an

50、d disability pay gap reporting?Organisations are increasingly prioritising ethnicity and other pay gap reporting as part of their DE&I initiatives.Below sets out some key actions to consider in preparation for this.14PwC|Mandatory UK Gender Pay Gap ReportingA reporting landscape glossaryReporting fr

51、amework/requirementDetailsUK Gender Pay Gap ReportingThe Equality Act 2010(Gender Pay Gap Information)Regulations 2017 requires employers with 250 or more employees to publish and disclose statutory gender pay gap reporting figures each year.FCA Listing RulesUnder listing rules from the FCA,UK liste

52、d companies from any industry need to disclose on a comply or explain basis gender and ethnicity representation levels of their Board and ExCo,noting the Board representation targets set by the FCA.The FTSE Women Leaders ReviewThe FTSE Women Leaders Review aims to increase the representation of wome

53、n in leadership positions of FTSE 350 companies,setting recommendations and targets for businesses to improve senior leadership gender balance.UK Ethnicity Pay Gap ReportingOrganisations are increasingly voluntarily publishing ethnicity pay gap reports.The Parker ReviewThe Parker Review addresses th

54、e ethnic diversity of UK companies.Its latest request is for FTSE 350 companies and the 50 largest private companies to set and publicly disclose a percentage target for senior management positions(which it defines as the Executive Committee and the level below)that will be occupied by employees fro

55、m an ethnic minority in December 2027.FCA and PRA Diversity and Inclusion RegulationThe FCA and PRA have published two Consultation Papers on diversity and inclusion(“D&I”)within financial services which included proposed requirements including the collection of D&I data,setting diversity targets an

56、d a D&I strategy,embedding non-financial misconduct into regulatory frameworks,and governance and accountability.The final Policy Statement is due to be published in late 2024.Investor GuidanceA number of investors and proxy bodies align themselves to diversity targets.For example the IA references

57、the FTSE Womens Leaders Review,the Parker Review and FCA rules and will“red top”companies on diversity for not meeting set targets.Some investors have their own guidance,for example LGIM will vote against the Chair of a listed organisation if less than 40%of the Board is made up of the underrepresen

58、ted gender.15PwC|Mandatory UK Gender Pay Gap ReportingReporting framework/requirementDetailsVoluntary Global Sustainability DisclosuresSustainability reporting frameworks established by organisations and institutions such as the World Economic Forum,Bloomberg and S&P Global provide useful guidelines

59、 and metrics for reporting on ESG.DE&I Reporting Standards/Best Practice FrameworksIncreasingly organisations are voluntarily reporting on DE&I metrics such as pay gaps,representation levels and pay equity on gender and broader diversity factors like gender identity,ethnicity,sexual orientation,soci

60、o-economic background,disability and veteran status.While practices may differ based on location,global organisations are generally expanding the types of DE&I reporting and diversity factors they cover in different regions.International Sustain-able Reporting Frame-works(CSRD,ISSB and SEC)Increasin

61、g demand for enhanced transparency about sustainability matters from stakeholders has driven definitive proposals in the form of The Big 3 disclosure frameworks:European Union(EU)as part of the Corporate Sustainability Reporting Directive(CSRD).Internationally by the International Sustainability Sta

62、ndards Board(ISSB).United States(US)by the Securities and Exchange Commission(SEC).These big 3 disclosure frameworks each detail expansive sustainability disclosure requirements including workforce and apply materiality judgements on what to disclose.For example CSRD alone requires companies to disc

63、lose people metrics and information that is assurable as defined in 51 pages of new regulation,17 Disclosure requirements and 20 quantitative metrics.This will have a significant impact for both EU and non-EU headquartered groups.EU Pay Transparency Directive(“EUPTD”)EUPTD will require organisations

64、 with any workers in EU member states to implement a series of measures to ensure pay transparency.These include external gender pay gap reporting,Internal equal pay assessments,employees having the ability to request information on individual pay level,prospective employees requesting pay informati

65、on and additional disclosures on pay philosophy.16PwC|Mandatory UK Gender Pay Gap ReportingFor more information on any of the above,please get in touch with our teamKaty BennettPwC|DirectorM:+44(0)7715 211 210E:Cait SpencePwC|Senior AssociateM:+44(0)7483 935 131E:Vivek RajparaPwC|Senior ManagerM:+44

66、(0)7872 815 685E:Sarah AshcroftPwC|Senior ManagerM:+44(0)7701 296 250E:Kasia JazeelPwC|ManagerM:+44(0)7483 407 110E:Riva PatelPwC|AssociateM:+44(0)7483 930 683E:17PwC|Mandatory UK Gender Pay Gap ReportingThis publication has been prepared for general guidance on matters of interest only,and does not constitute professional advice.You should not act upon the information contained in this publication without obtaining specific professional advice.No representation or warranty(express or implied)is given as to the acc