More reporting requirements for large companies

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The reporting burden on companies, particularly large companies, is increasing year on year.

Modern Slavery Act 2015

First came the Modern Slavery Act 2015 and its requirement that Modern Slavery Act and its requirement that all companies carrying on business in the UK with a turnover of £36 million or more publish a statement noting the steps they have taken to ensure their supply chains are free from slavery and human trafficking. This obligation applies to companies with accounting year ends after 31 March 2016 and guidance suggests that the statement be made within six months of the year end. We may therefore see a steady increase in statements from September. We have written previously on this.

“Gender pay gap”

From 1 October this year, regulations will come into effect requiring employers with over 250 employees to publish details of their “gender pay gap”. Employers must take a “snapshot” of gender pay data within their organisations as at 30 April 2017 and publish their first gender pay report on their website by 30 April 2018.  Draft regulations and guidance have been published. Employers will be required to include analysis of pay and bonuses when preparing the report.  We have reviewed the gender pay gap reporting regulations previously.

Payment practices

The Small Business, Enterprise and Employment Act 2015 obliges large companies to publish a report on payment practices, policies and performance.   A “large” company for these purposes is one that satisfies two of the following criteria:

  • an annual turnover over £36 million
  • a balance sheet total over £18 million
  • on average, more than 250 employees

The new rules were originally intended to enter into force in April this year but have been delayed and 1 October 2016 is the new likely start date.  From that date, qualifying large companies (and LLPs) will have to publish and update every six months information relating to their payment practices and policies for business-to-business contracts under which they are supplied with goods, services or intangible assets and explain how they have performed in relation to those practices and policies.