Furlough and gender pay gap reporting: useful guidance

19 November 2020

Although gender pay gap reporting deadlines were suspended for the 2019-20 reporting year, due to the outbreak of coronavirus, there has been no indication that the deadlines will also be suspended for the 2020-21 reporting year. Employers who are required to submit gender pay gap data may be interested in an update on how furlough will impact the calculations that are involved in the reporting process.

The Government Equalities Office has confirmed as follows.

Employees who were paid less than their standard pay due to being on temporary leave should be considered as relevant, but not as full-pay relevant employees, which means that any furloughed employees must be counted when establishing what the employer headcount is, and included in the gender pay gap calculations, when:

  • Calculating the percentage of men and women receiving bonus pay
  • Calculating the average (mean) gender pay gap using bonus pay
  • Calculating the median gender pay gap using bonus pay

These calculations are made using relevant employees and so should include any employees that were placed on furlough.

Furloughed employees that received less than full pay would not count as full-pay relevant employees, due to the fact that they were paid a reduced rate as a result of being on a period of leave. Employees on furlough who received less than full pay must be excluded from gender pay gap calculations when:

  • Calculating the average (mean) gender pay gap using hourly pay
  • Calculating the median gender pay gap using hourly pay
  • Calculating the percentage of men and women in each hourly pay quarter

Furloughed employees receiving less than full pay do not count as full-pay relevant employees, as they were paid a reduced rate due to being on a period of leave. You must exclude employees on furlough who received less than full pay in your gender pay gap calculations when:

  • Calculating the average (mean) gender pay gap using hourly pay
  • Calculating the median gender pay gap using hourly pay
  • Calculating the percentage of men and women in each hourly pay quarter

If employees had their salaries topped up to their normal levels whilst on furlough, then they would also count as full-pay relevant employees for the purposes of calculations. If any employees agreed to defer a portion of their earnings, and were not placed on furlough, they would also be considered as full-pay relevant employees as they were not paid at either a reduced rate or nil as a result of being on leave.

CIPP comment

The Policy team would be interested in hearing from you – please send any comments or feedback you may have on this mandatory reporting requirement, particularly given the current challenging circumstances we find ourselves in, to Policy@cipp.org.uk.


The information in this article is accurate at the time of publication. For all the latest information, news and resources on how the COVID-19 pandemic is affecting payroll professions, visit our Coronavirus hub.