Including furloughed employees in gender pay gap reporting

For the 2020 to 2021 reporting year

This guidance provides information on gender pay gap reporting for employers who may have had changes to their workforces as a result of coronavirus (COVID-19).

It applies to the 2020 to 2021 reporting year, which uses a snapshot date of 31 March 2020 or 5 April 2020.

Find out which snapshot date applies to you on the GOV.UK website.

If you are required to submit your gender pay gap information for the 2020 to 2021 reporting year, you must include all furloughed employees:

• when determining your employer’s headcount
• whose salaries were topped up to their usual full pay

You must exclude employees receiving less than full pay who were on furlough on your snapshot date when calculating:

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

Furloughed employees whose salaries were not topped up to full pay, and so were on temporary leave and being paid at a reduced rate should be excluded from these three calculations.

All other reporting requirements remain unchanged.

Employees furloughed under the Coronavirus Job Retention Scheme (CJRS) on your snapshot date are on a period of temporary leave.

They are still employed by you.

All furloughed employees count as relevant employees when determining your employer’s headcount.

Relevant employees are those employed by your employer on your snapshot date.

Include all employees on furlough in your gender pay gap calculations when:

• working out if you have a headcount of 250 or more employees (for example, an employer of 261 employees that had 50 employees on furlough would still be required to report their gender pay gap)
• 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 be calculated including employees on furlough.

Furloughed employees whose salaries were topped up to their usual full pay are full-pay relevant employees and should be included in all calculations.

If any of your employees agreed to defer part of their earnings (for example, due to the impact of COVID-19 on your employer’s finances), and they were not placed on furlough, they would be considered full-pay relevant employees because they were not paid at a reduced rate or nil as a result of being on leave.

You must still include these employees in all your gender pay gap calculations because they are considered full-pay relevant employees.

Furloughed employees receiving less than full pay do not count as full-pay relevant employees, as the reduction in their pay was because they were on a period of temporary leave.

They must be excluded from some of the required gender pay gap calculations.

Full-pay relevant employees are those who were paid their usual full pay in their pay period that included your snapshot date.

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

These calculations only include full-pay relevant employees, and furloughed employees who received less than full pay do not count as full-pay relevant employees.