Gender and ethnicity pay gap: data reporting and legal requirements
The Royal Institute of British Architects (RIBA) has developed this best practice guidance for RIBA Chartered Practices. We are keen to encourage practices of all sizes voluntarily to evaluate their gender and ethnicity pay gap data, and share it if willing and, more importantly, to take the most effective recommended actions to improve their gender equality and benefit the wider profession.
Very small practices may encounter confidentiality issues when disclosing gender and ethnicity pay data by quartiles, but they should usually be able to safely develop and implement an action plan and their headline data (both mean and median).
Legal requirements
From 6 April 2017, the UK government required all legal entities that employ 250 or more people to publish a Gender Pay Gap report on an annual basis. Currently, it is only a requirement to publish the data report relating to gender, but we encourage practices to also track ethnicity data where possible to highlight intersectionality and identity gaps.
All employers with 250 or more employees must calculate and publish the following data. They may also choose to publish a commentary on progress made since the previous year’s report, explaining any actions taken to improve the Gender Pay Gap and any changes in the reported data:
- mean gender pay gap
- median gender pay gap
- mean bonus gender pay gap
- median bonus gender pay gap
- proportion of men in the organisation receiving a bonus payment
- proportion of women in the organisation receiving a bonus payment
- proportion of men and women in each quartile pay band
This information must be recorded publicly, such as on your practice website, and must also be reported in conjunction with the Gender Pay Gap service. Organisations with fewer than 250 employees can also choose to disclose a Gender Pay Gap Report voluntarily.
Recommendations
The recommendations in this guidance are based on those of the Government Equalities Office and other research into the issues underlying the Gender Pay Gap as well as effective actions to address them. It draws on analysis and reports by other organisations in addition to our own qualitative research with other practices that currently, or will soon, share their own gender and ethnicity pay gap reporting.
These recommendations set out workable measures that can be put in place by practices to enable currently underrepresented individuals to stay in the profession and reach senior levels, thereby closing the gender and ethnicity pay gap.
Specifics of reporting ethnicity pay gap
While the methodology for determining the ethnicity pay gap is similar to that of gender pay calculations, it is more complex. Unlike gender, your practice may only collect ethnicity data through voluntary declaration and therefore an accurate analysis requires 100% of colleagues to submit this data voluntarily.
Due to this, you may wish to encourage colleagues to update diversity information, enabling you to generate more insights and take steps to become a more inclusive place to work.
Collecting ethnicity data may also be made more complex due to the number of colleagues within different ethnic groups in your practice. The guidance recommends only conducting pay calculations where there are a minimum of 50 colleagues in an ethnic group; this is to ensure a larger data set to avoid possible identification of individual colleagues.
Depending on the size of your practice, you may wish to create larger groupings to ensure each group has a minimum of 50 respondents.
Any report should aim to help employers and employees understand why a pay disparity might be present and what has been – or will be – done to analyse and improve it.
