How is bonus defined for the purposes of reporting an organisation's gender pay gap and gender bonus gap?

Under the draft Regulations that set out the gender pay gap reporting duty, as well as reporting the difference in pay (which includes bonus pay) between their male and female employees, employers must report on the difference in mean bonus pay and on the proportion of male and female employees who received bonus pay. The Government has indicated (in its consultation on mandatory gender pay gap reporting for public-sector employers) that the Regulations will be amended to include an additional requirement to publish the difference in median bonus pay.

Bonus pay is defined broadly under the draft Regulations. It includes:

  • all bonus payments (including profit-sharing, productivity, performance and incentive payments, piece work and commission);
  • long-term incentive plans or schemes (including those based on company or personal performance); and
  • the cash equivalent value of shares on the date of payment.

All bonus pay should be included in the calculations, regardless of whether the bonus is discretionary or contractual.

In relation to long-term incentive plans, it is the amount that is received during the relevant 12-month period that should be included, not the amount that is awarded.