UK: Gender Pay Reporting and Transparency
Published on 3rd September 2025
There is no requirement for the UK to implement the Directive and we do not expect the UK government to introduce any measures specifically addressing the Directive.
However, the Directive goes further than existing UK requirements and employers operating in the UK will need to consider the implications of the Directive on their wider organisation and whether or not to align policies more generally with the requirements of the Directive.
What is the current position?
- Gender pay reporting
In the UK, employers with 250 or more employees on a "snapshot date" (5 April each year for private sector employers) must report specific gender pay information. A written report confirming the accuracy of the information must be produced and uploaded to a government website. Non-statutory government guidance is available to support employers with the reporting process.
At present, the statutory rules do not require employers to take any steps to close any gender pay gap identified; the Equality and Human Rights Commission may take enforcement action but the statutory rules do not include any penalties or enforcement mechanisms for non-compliance.
- Pay transparency
There are no legal requirements requiring employers to disclose initial pay levels or ranges in job adverts or which prohibit inquiries about the pay history of job applicants.
Workers also do not have a legal right to request individual and average pay data by gender for comparable roles.
Future reforms
The UK Government has not indicated that it will be introducing any reforms directly to align with the Directive.
Under the Employment Rights Bill which is currently proceeding through Parliament there is a proposal for employers with 250 or more employees to publish action plans as part of their annual gender pay gap reports.
The government is also consulting on introducing mandatory ethnicity and disability pay reporting for large employers and which will form part of a separate Bill.
Return to main EU Pay Transparency Directive page
