Tuesday 30 April 2024

2025 Gender Pay Gap reporting: everything you need to know

by Hannah Sturrock, National Head of Engagement, Advertising Council Australia.


When the Workplace Gender Equality Agency (WGEA) published employer pay gaps in February, it was headline news for a few days.

It was the first time WGEA had published individual employer gender pay gaps–albeit with CEO salaries excluded – and the opportunity to examine and compare the raw and unfiltered numbers shone a spotlight on workplace gender equality in Australia, and in adland.

There were various statistics cited and they all measured slightly different things. Here’s a quick reminder:

  • The median or mid-point total remuneration pay gap for employees was 19%
  • The mid-point gender pay gap for all employers was 9.1% i.e. half have gaps above and half have gaps below
  • At an industry level, Construction has the largest median total remuneration gender pay gap at 31.8%
  • Accommodation and Food Services has the lowest at 1.9%.
  • For our industry sector – Professional, Scientific and Technical Services (except computer system design and related) – the median total remuneration gender pay gap for employees was 25%
  • For our industry sector – the median employer gender pay gap was 16.1%



The impact of this transparency leads to accountability and should ultimately catalyse change, especially as both clients and prospective talent ask more equity-related questions of agencies.

While the news spotlight has moved on from this year’s data release, it’s important to keep the momentum going for the next round, with 2025’s submission deadline only weeks away with publication likely to be February 2025.

Here’s a quick rundown of what’s changed and the resources available to help.

Who needs to submit?

  • Any employing entity who has employed in total 100 or more employees for 6 months or more of a reporting period
  • A corporate structure with 100 or more employees in total across all entities
  • Employers whose employee count has recently dropped below 100 in total must keep reporting until they have employed fewer than 80 employees in total for the majority of the reporting period April 1 2023 – March 31 2024.

Can I get an extension?

  • Submissions are made in the WGEA Portal during the two-month submission period: 1 April to 31 May
  • Edits can be made in the 28 days post-submission
  • Request an extension before 31 May and you’ll automatically get an additional four weeks. Longer extensions require a formal assessment.

What is changing in 2024/2025?

Be prepared for some important changes to the way data is collected and reported.

  • Inclusion of CEO remuneration
    – WGEA will include CEO remuneration in gender pay gap calculations next year
    – The inclusion of CEO remuneration will be a more accurate representation of the gender pay gap as currently, 78% of CEOs of private sector employers with 100 or more employees in Australia are male
    – Based on current voluntary data once CEO data is included approximately 20% of employers will have their GPGs decrease, and 70% of employers will increase
  • Company reporting versus holding company reporting
    – In 2025, WGEA will publish employer gender pay gaps for each ABN within a corporate structure that employs 100 or more employees
    – It will also publish a report for the overall parent company
    – This means individual agency brands with more than 100 people should be thinking about their strategy and communications plan rather than mirroring or deferring to the parent company
  • Questions about flexible work
    – This year, employers will be asked whether managers receive appropriate support to conduct performance evaluations that are not influenced by the work location or employment basis of the employee e.g. part-time
    – Training, guides and standard evaluation processes are some examples of support that can mitigate the favouring of in-office and full-time workers, by managers
  • Reporting on sexual harassment or discrimination policies and prevalence
    – Additional information about sexual harassment and discrimination will be mandatory this year, including:
    Questions about your policy or strategy and what is included
    Whether you provide training on sexual harassment, how frequently, and what is covered
    – ACA members can watch our Create (Safe) Space briefing on Respect@Work for more information

Median versus average pay gaps – please explain.

Yes, we vaguely remember this from Year 8 maths but details are fuzzy.

In 2024, WGEA only reported on the median gender pay gap. In 2025, they will report on both the median and the average.

The median is the value that falls exactly in the middle of a set of numbers when arranged from
smallest to largest. The median gender pay gap is the difference between the median of what a man is paid and the median of what a woman is paid within an organisation.

The average gender pay gap is a good measure of the collective remuneration of a group. As the average is skewed by exceptionally high or low salaries, it will show if earnings are particularly concentrated for one gender, for example, more men in higher earning positions.

What should we be doing if we have a significant gender pay gap?

Audiences understand that improving gender equality is a process. The key is showing there is a commitment and a process to improve.

While the gender pay gap is a proxy for gender equality, it may not provide a complete picture of an organisation’s commitment to it.

One of the best ways to demonstrate your commitment is to upload an Employer Statement to accompany your data. By failing to upload one, a sub-optimal pay gap only looks worse.

  • As of 18 March 2024, only 20% of employers have provided a working link to an Employer Statement
  • For 80% of employers, this is a huge opportunity to provide context for your numbers and outline what you’re doing about it
  • It’s not too late for 2024, employers can upload a link at any time and WGEA will regularly update the Data Explorer
  • Read the Employer Statement Guide for more information

A key component of your action plan will include commitment to training.

We’re new to this and we still need more help.

WGEA is running free 90-minute capacity-building masterclasses to help employers deepen their understanding of workplace gender equality and take effective action to narrow their gender pay gap. Current sessions include:

  • Conducting a gender pay gap analysis – obtaining key insights from data to focus your action plan
  • Gender Equality Action Planning – choose, prioritise and plan gender equality actions uniquely targeted to your organisation to effectively narrow your gender pay gap and increase gender equality in your organisation.

On 11 April 2024, WGEA hosted a very helpful one-hour webinar that answered the most common questions about employer gender pay gaps, such as how to calculate the annual total remuneration of a ‘part-year’ employee, how to report ‘potential’ earnings and more detail on the changes for 2025.

There are lots more resources on the WGEA website too.

How you respond when you identify a gender gap is more important than the reporting itself.

Think about how changing policies and practices in key areas, including recruitment, talent, development, training, remuneration and retention, can move the needle and remove bias. Then work on enhancing the availability and uptake of shared parental leave and re-think or redesign part-time roles for managers.
If managers aren’t sponsoring women for advancement, incentivise them to do it.

This step of public reporting is just the beginning towards closing the gap. Companies have always had the gender gap data at their fingertips to start this process – but now the public has that data, too.

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