
Rules and ethics
Which gender pay gap figures can UK employers use in employer branding?
Employer branding can cite mean and median gender pay gap figures from GOV.UK, but equal pay claims and adjusted gaps must stay out of the copy.
What to take away
- Employer branding may quote the mean and median gender pay gap figures your organisation has published on the GOV.UK gender pay gap reporting service, because those numbers are already public.
- Employers with 250 or more employees must report by the snapshot date and deadline set for the current reporting year.
- Bonus gap figures are reportable too, and they usually look worse than the hourly gaps.
- Equal pay claims, adjusted gaps and figures for a hand-picked part of the workforce are not gender pay gap figures and should not be used as if they were.
- A short narrative alongside the numbers does more for recruitment marketing than a single headline percentage.
Who must report under the GOV.UK gender pay gap service
The duty applies to employers in England, Scotland and Wales with 250 or more employees on the snapshot date. Those employers publish six figures through the GOV.UK gender pay gap reporting service, where anyone can search them.
Who must report under GOV.UK
250+ employees in England, Scotland, Wales?
publish six figures on GOV.UK
no statutory duty, voluntary possible
That public visibility is the whole reason the figures are usable in employer branding. You are not revealing anything a candidate could not find in two clicks. You are choosing to talk about numbers that are already on a government website.
The duty sits on top of older equality law. The Equality Act 2010 sets out the protected characteristics and the equal pay provisions that gender pay gap reporting was built to expose, and you can read the Equality Act 2010 in full on the legislation site.
Government guidance on those employment duties sits alongside it.
Below 250 employees there is no statutory duty, though some smaller employers report voluntarily. If you do, say so plainly. A voluntary disclosure reads as confidence; a vague claim about being "transparent on pay" without a number reads as avoidance.
Groups are covered too. A parent company and its subsidiaries count employees together for the threshold, so a group can be in scope even when no single entity employs 250 people.
What the six published figures are
Every in-scope employer publishes the same set. That set covers the mean hourly gap, the median hourly gap and the four pay quartiles.
It also covers the mean bonus gap, the median bonus gap, and the proportion of men and women who received a bonus.
That fixed set is what makes comparison possible. If you quote a figure that is not in the set, you are not quoting your statutory reporting, whatever the spreadsheet says.
Reporting thresholds, deadlines and the snapshot date
The snapshot date is the date on which you count employees and capture their pay. For private and voluntary sector employers it falls in March or April, and the deadline to publish falls twelve months later. Public sector employers work to a different snapshot and deadline.
Snapshot to publication cycle
- March/AprilSnapshot date for private employers
- Twelve months laterPublication deadline
- Three yearsData stays online
So the figures you publish in one year describe pay on a single day roughly a year earlier. This matters for employer branding, because a gap you have since closed is still the gap on the register until the next cycle replaces it.
You must publish within the deadline, and you must keep the data online for at least three years. Late publication is itself a story, and not one you want a candidate to find before you have told it yourself.
Use the employer branding key metrics you already track to decide which of the six figures to lead with, and check your own reporting calendar before you promise a campaign date.
A worked example
Suppose a Manchester employer with 600 staff reports a median hourly gap of 9.4 per cent and a mean of 13.1 per cent. The mean is higher because a small number of very highly paid men pull it up.
The same employer reports a mean bonus gap of 31 per cent. That is normal and it is not a scandal, but it is the figure a journalist will pick out.
If the employer wants to run recruitment ads in the North West, the honest line is the median, with the bonus gap named in the same paragraph. Quoting 9.4 per cent alone invites the accusation that you buried the rest.
Mean, median, quartiles and bonus gap: which figures exist
The mean gap is the difference between average hourly pay for men and average hourly pay for women, as a percentage of men's average. The median is the difference between the middle man and the middle woman when everyone is lined up in order.
Mean versus median gap
Mean
- What it is
- Average difference
- High earners
- Pulled up
- Typical size
- Larger
- Question
- Average pay
Median
- What it is
- Middle difference
- High earners
- Less sensitive
- Typical size
- Smaller, friendlier
- Question
- Typical pay
The median is less sensitive to a handful of very high earners, which is why it is usually the smaller and friendlier number. Neither is more true than the other. They answer slightly different questions.
Quartiles split your workforce into four equal bands by hourly pay and show the gender split in each. They explain the headline: if your upper quartile is heavily male, your gap is a structure problem, not a pay policy problem.
Bonus gap figures compare mean and median bonus pay, plus the proportion of men and of women who received any bonus at all. Part-time work and bonus eligibility rules drive much of what you see here.
All of these are workforce-wide figures. They say nothing about whether two people doing the same job are paid the same, which is a separate legal question.
Where the benchmark numbers come from
When you want to say your gap is better or worse than the norm, use published national earnings data rather than a figure from a supplier deck. The Employee earnings in the UK - Office for National Statistics release gives the annual picture of earnings by occupation and region.
For shorter-run movements, the Average weekly earnings time series - Office for National Statistics lets you check whether a change you are claiming is real or just noise. Cite the release, not a screenshot.
Which gender pay gap figures employer branding can legitimately cite
You can cite any of the six published figures, provided you cite them accurately, attribute them to the reporting year, and do not imply they measure something they do not.
Safe uses of the six figures
Figure
- Mean hourly gap
- Quote with median
- Median hourly gap
- Usual headline
- Quartiles
- Explain the cause
- Mean bonus gap
- Name alongside hourly
- Median bonus gap
- Same rule
- Proportion receiving bonus
- Bonus eligibility split
Safe use
- Mean hourly gap
- Median hourly gap
- Quartiles
- Mean bonus gap
- Median bonus gap
- Proportion receiving bonus
The safest framing is factual: "Our median hourly gender pay gap for the 2025 reporting year was X per cent, down from Y per cent." That sentence is checkable in seconds and survives scrutiny.
You can also cite the direction of travel, but only where the figures support it. Gaps move for reasons other than your actions, including changes in headcount and in who holds senior roles.
You can cite your own published report as a source, linking to your GOV.UK entry. That link does more for trust than any badge.
And you can cite national data to give context, as long as you name the source and the period. Context is not the same as excuse, and readers can tell the difference.
Which figures employer branding can cite
| Figure | What it measures | Safe employer branding use |
|---|---|---|
| Mean hourly gap | Average hourly pay difference | Quote with the median, never alone |
| Median hourly gap | Middle-of-the-range difference | The usual headline figure |
| Quartiles | Gender split by pay band | Use to explain the gap's cause |
| Mean bonus gap | Average bonus difference | Name it if you name the hourly gap |
| Median bonus gap | Middle bonus difference | Same rule as above |
| Proportion receiving a bonus | Bonus eligibility split | Useful for part-time and eligibility context |
Keep the claim to one reporting year
A common error is to quote a good year and imply it is current. If the register shows a different figure for the latest year, a candidate will find it.
State the reporting year in the sentence itself. "In the 2025 reporting year" costs four words and removes the ambiguity.
Figures you must not quote: equal pay, adjusted gaps and cherry-picking
Equal pay is not the gender pay gap. Equal pay is the legal requirement to pay men and women the same for equal work, and it is enforced through the Equality Act 2010 and the tribunal system, not through the reporting service. Government guidance on those employment duties explains the difference.
Figures you must not quote
- Equal pay claims under Equality Act 2010
- Adjusted gaps controlling for level or hours
- Single business unit or region gaps
- Unsubstantiated pay claims under CAP Code
The Equality Act 2010: guidance - GOV.UK is the plainest place to check what the law requires before you write anything that sounds like an equal pay claim. If your copy says you "pay men and women equally", you have made a legal claim, not a marketing one.
Adjusted gaps are the other trap. An adjusted figure controls for job level, tenure, hours or location, and it is a legitimate analytical tool. It is not one of the six published figures and it cannot be presented as your gender pay gap.
Cherry-picking is the third. Quoting a gap for one business unit, one region such as the South East, or one grade while implying it covers the whole company misleads the reader, even if every number is accurate.
There is also a regulatory backdrop most employers forget. The Advertising Standards Authority applies the CAP Code to recruitment advertising, including employment ad rules, and a pay claim that cannot be substantiated is a complaint waiting to happen.
The Information Commissioner's Office covers the data side. If you are pulling pay figures into a campaign, or using software to draft pay messaging, UK GDPR and the ICO's AI guidance both apply to how that data is handled.
A written employer branding disclosure policy settles most of these arguments before a campaign starts. Decide who approves a pay claim, which figures are in scope, and what happens when someone asks for the source.
Narrative reporting and the employer brand story around the numbers
The figures alone are not a story. The narrative is where you explain what causes the gap, what you are doing about it, and how you will know it has changed.
Good narratives name the mechanism. If your gap is driven by few women in senior engineering roles, say that, and say what you are doing about hiring and progression.
They also separate the causes. Occupational segregation, part-time working patterns and bonus eligibility each push the numbers in different directions, and a reader who works in reward will spot a narrative that lumps them together.
Avoid promises you cannot keep within a reporting cycle. A target to halve the gap in two years, when the drivers are structural, damages credibility when the next set of figures lands.
Bring in the wider inclusion agenda rather than treating pay as a standalone number. The Equality, Diversity and Inclusion resources | CIPD cover how pay messaging sits inside broader inclusion work, and they are a reasonable citation for a careers page.
Where the law and ethics overlap, the rules and ethics apply to every claim you publish, not just the ones in a formal report. A careers page is advertising.
Publishing the narrative in more than one place
The report on GOV.UK is fixed. Your careers site, job adverts and recruiter briefings are yours to write, and they should carry the same numbers with the same year attached.
Brief your recruitment partners. Agencies working under REC standards will repeat whatever you give them, so give them the approved sentence and the source link.
Checking a supplier's pay gap claims before you publish
Agencies and pay data suppliers quote gaps constantly, and some of those numbers do not survive a check. Before anything goes on a careers page, verify it.
Verify supplier pay gap claims
- Ask which figuremean, median, bonus, quartile
- Ask reporting year and GOV.UK source
- Check employer on GOV.UK reporting service
- Check company at Companies House
- Ask what was excluded
- Get source in writing with link
A supplier who cannot answer these questions is not necessarily dishonest. They may be quoting an adjusted figure without labelling it. Either way, the claim is not yours to publish.
A short pre-publication checklist
- The figure matches the employer's latest GOV.UK filing.
- The reporting year is stated in the copy.
- Mean and median are not mixed up.
- Bonus gaps are included where hourly gaps are quoted.
- No equal pay claim is implied anywhere in the text.
- Adjusted figures are labelled as adjusted, or removed.
- The source link is live and points to GOV.UK or the ONS, not a screenshot.
Keep the checklist with the campaign file. When someone challenges a figure eighteen months later, the file is your answer.
Common questions
Can we quote our gender pay gap in a job advert?
Yes, if you quote one of the published figures accurately and name the reporting year. Avoid turning it into an equal pay claim, and keep the wording consistent with your published report.
What if our gap has improved since the last snapshot date?
You can explain the change, but you cannot present an unpublished internal figure as your gender pay gap. Say the latest published number and describe the direction of travel separately.
Do we have to report if we have 250 employees in one month only?
The threshold is assessed on the snapshot date, so a temporary spike may or may not bring you into scope. Check the headcount rules for the specific snapshot before you decide.
Is the median always the better figure to use?
The median is usually the more stable headline, but it is not automatically better. If your mean is much higher, a reader who checks the register will see it, so address both.
Can we use a bonus gap figure from a previous year?
Only if you label the year clearly. Mixing an old bonus figure with a current hourly figure is the kind of cherry-picking that undermines an otherwise honest report.
Who signs off pay claims in our recruitment marketing?
That is your call, but it should be written down. Reward, HR and legal each have an interest, and a named approver prevents a figure reaching a job board unchecked.



