As we move towards the end of the year, it’s a good time to remind ourselves that we are nearing the December 2023 Gender Pay Gap reporting deadline.
If you are an employer with 250 or more employees and have not yet prepared your report, you need to take action immediately. At Mazars, we have helped a multitude of organisations since the legislation came into force and can support you, partnering with you to fulfil your obligations and report on time.
Gender pay gap reporting has been mandatory for both public and private organisations with a headcount of 250 employees or more since the Gender Pay Gap Information Act was signed into law in 2021. Organisations with 250 employees or more published their first reports last December, and the annual deadline is set to December of each year going forward.
From 2024, the scope will widen to include organisations with 150 employees so it is also a good time for those who will be reporting for the first time next year to familiarise themselves with the requirements and contents of the report and begin to prepare.
Pointers to support your 2023 submission
If you’re still working on your Gender Pay Gap data for the year, here are some pointers to support your calculation and submission before the deadline in December.
- In order to have a consistent set of data to analyse, create a data template, which involves stitching together multiple sets of data. Without harmonising payroll and HR data, there can be gaps in calculating the GPG figures.
- The quantitative methodology used to calculate GPG is, on paper relatively straightforward, however there are several complexities in accurately cleansing and assessing data which are often misconceived. The snapshot is often misconceived, rather than assessing the data on just the chosen snapshot data, which is the case in the UK, in Ireland employers must examine the full twelve months of data prior to that date, including:
- Pay increases
- Paid leave
- Unpaid leave
This data can often come from different systems, which require extensive work to stitch together.
- Conduct a cleansing exercise to address any anomalies.
- Qualitative findings and recommendations are the result of a documentation review and analysis of the infrastructure, practices and processes in place within your organisation. There are four parts to the work:
(1) Strategy – Representing the organisational DE&I infrastructure
(2) Policies – What employee policies are in place and how do they impact the employee lifecycle
(3) Processes – what processes are in place that impact the employee lifecycle?
(4) Practices – How do these policies and procedures translate to real-life action?
What have we learned from year one?
Mazars has found that there have been a number of challenges arising from the first year of reporting. Qualitative research proved to be challenging for many organisations, as reporting requirements had changed from the initial legislation, and government guidance on the subject was not comprehensive.
Combining data: Employers have found the process of combining payroll data with HR data challenging and onerous. Furthermore, there have been complications with employers who changed outsourced payroll providers during the twelve-month period, as this required stitching together multiple data sets in different formats.
Anomalies: While a vast majority of employees within an organisation are straightforward to calculate for, a small number of employees with anomalies in their data take a disproportionate amount of time to investigate and resolve. This is particularly prevalent in organisations with limited HRIS infrastructure or where human error disrupts data.
Bonus pay: There are gaps in the legislation’s reporting requirements around bonus pay, which can cause confusion.
“Where the bonus period is not the same as the reporting period being used for the calculation, then only the bonus relevant to the 12-month reference period should be included. If a bonus is paid within the 12-month period but includes a payment in respect of a period of time prior to those 12 months, that element should be excluded”
Adjustments: It can also be challenging for employers to calculate for employees who had their contractual hours and remuneration adjusted during the course of the year.
Year two reporting and beyond
Looking ahead, plans are in place to establish a central reporting system, which will be a welcomed step. Until then, employers will continue to report their GPG reports on their websites or somewhere publicly accessible.
There is a sense of momentum happening surrounding the topic of equal pay and gender equality at work, not only at a local level but across the EU. The EU Pay Transparency Directive came into effect on 6 June 2023 and seeks to combat pay discrimination across EU states. The new rules will contribute to closing the gender pay gap. Ireland must implement the additional obligations by June 2026. These new rules will further increase the workload for employers but will pave the way forward towards greater gender equality, ensuring pay transparency in the workplace across multiple areas.
How we can help
Mazars understands the pressure organisations are facing. Employers already in the reporting process are not ‘finished’ once they have accumulated and organised the required data. What employers do with the data and how they outline actions to address gaps is equally important in the public eye.
Using our bespoke GPG analysis tool, we can calculate your gender pay gap in accordance with legislative requirements. Once you have identified your GPG, we can help you design, develop, and implement initiatives to address the gap noted.
This includes action plans, D&I frameworks, culture reviews, D&I strategies, recruitment and selection techniques and training, amongst other things. We can also develop data models to determine the impact that certain initiatives or actions may have on your gender pay gap over time.
Contact us today to discuss how we can help streamline this process for you, making sure your organisation stays on top of this important development in ensuring equity in our employment landscape in Ireland.