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Gender Pay

Policy recommendations

What you need to know


Gender Pay Strategy and Pay Reporting - Policy Recommendations

Policy recommendations:

Gender Equality
We call for prompt action to bring Section 19 of the Employment Act (Northern Ireland) 2016 (‘the Act’) into force, and to introduce a gender pay strategy and associated action plan, in tandem with the introduction of Gender Pay Gap Reporting Regulations (‘the GPGR Regulations’), in Northern Ireland.



The Act provides for the making of GPGR Regulations (by 30 June 2017), and requires the publication of a gender pay strategy/action plan within 18 months of the Act receiving Royal Assent.  However, to date, these provisions have not been brought into force, nor has any underpinning consultation on draft GPGR Regulations or on a gender pay strategy/action plan been commenced.  Our recommendations for Government, summarised below, have been informed by the views of a number of stakeholders, including representatives from trade unions, the women’s sector and employer organisations.  

Employment Act (Northern Ireland) 2016: Bring Section 19 into force, updated as required & support good practice

Employment Act (Northern Ireland) 2016 (the Act): Bring Section 19 of the Act into force, updated as required; and support good practice prior to its enactment.


Government should urgently bring into force Section 19 of the Act, updating provisions where required, including timelines for compliance with the duties and responsibility for implementing the duties. Given delays to enactment, immediate action should be taken to encourage and support employers to proactively address pay gaps.



Gender Pay Strategy: Implement a gender pay strategy in tandem with GPGR Regulations beginning work immediately

Gender Pay Strategy: Implement a gender pay strategy and action plan for Northern Ireland, beginning work without further delay to allow this to occur in tandem with GPGR Regulations.


Government should promptly implement a gender pay strategy and action plan for Northern Ireland to address structural factors within society and the workplace; and should commit to introducing this strategy and action plan in tandem with the implementation of the GPGR Regulations, beginning work without further delay to allow this to occur.



GPGR Regulations: Introduce Regulations, initially apply to large employers, review after 5 years, encourage good practice

Gender Pay Gap Reporting (GPGR) Regulations: Introduce GPGR Regulations; initially apply requirements to large employers; review after 5 years; and encourage all employers to address gender pay gaps


The GPGR Regulations should be introduced as a matter of urgency. The GPGR requirements should initially apply to employers with 250 or more employees. The Regulations should be reviewed after 5 years, to include a review of employer threshold size and their general operation. Employers not subject to GPGR requirements should be encouraged to proactively address gender pay gaps.



Employer Duties: Require publication of gender pay data; consider additional requirements; clarify Act

Employer Duties: Require publication of gender pay gap data; consider additional pay gap reporting requirements; and clarify provisions of the Act.


Action is required to: require employers to publish data on gender pay gap, bonus gender pay gap, and proportion of males / females receiving bonuses and in each quartile band; consider requiring employers to publish full-time and part-time gender pay gap figures; clarify rationale for limiting requirements to publish data on ethnicity and disability; clarify the specific intent of the requirement to publish pay data on ethnicity and disability; consider data to be published versus a wider set of data that employers can collect/ analyse; clarify rationale for the focus on ‘employees’ and/or ‘workers’; require publication of gender pay data on a common fixed date on employer/government websites; and consider coding of employers by SIC.



Employer Gender Pay Action Plans: Support employers; employers consult/publish plans, address ethnicity/disability gaps

Employer Gender Pay Action Plans: Ensure gender pay strategy supports employer actions; clarify employer requirements; and ensure employers: consult on, and publish action plans widely; consider actions to address ethnicity/ disability pay gaps; and review annually.


Action is required to ensure that actions required by employers are supported by the content and delivery of a gender pay strategy and action plan for Northern Ireland; to clarify requirements on employers as regards action plans; and ensure employers should: publish action plans on employer/government websites; consult with employees on action plans; consider actions to address ethnicity/ disability pay gaps; and review action plans at least annually.



Guidance, Compliance & Enforcement: Support employers; ensure effective enforcement & consider roles/resourcing

Guidance, Compliance and Enforcement: Ensure support for employers; highlight benefits of alignment with existing equality reviews; ensure effective enforcement mechanisms; and consider roles and resourcing


Action is required to ensure effective support and guidance for employers; to highlight via Guidance potential benefits of aligning action planning with existing employer equality reviews; clarify enforcement and compliance provisions and ensure effective enforcement mechanisms; set out advice/ guidance roles and remit and resourcing; and set out enforcement roles and remit, and resourcing.



Further information

Equal Pay - Guidance 
A consideration of gender pay gaps is seperate from, and different to, that of 'equal pay'.



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