If you thought your firm was exempt from the gender pay gap regulations, please think again. A recent clarification from the Government has suggested that the definition of 'employee' is wider than originally thought. The regulations do not just require reporting on employees but also agency staff, atypical workers, LLP members, casual staff and even self-employed contractors. This may well take your business over the reporting threshold which kicks in when your business has 250 or more 'employees'. We await the publication of the final form regulations this year, which will confirm exactly which staff are caught by the regulations. In this interim period, if you are doing dry run, we encourage you to collect data, on a privileged basis, on the pay received by all of your staff who fall into the above category. This exercise will give your organisation an insight into what the data for your business will look like at the snapshot date next year and give you time to make changes if you feel it is necessary.

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