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From data to action: Why Scotland needs mandatory gender pay gap action plans
For more than ten years, Scotland’s public sector has been required to publish gender pay gap data. Yet despite years of reporting the figures remain stubbornly high, and progress has stalled. Too often, employers stop at publishing the numbers, without setting out how they will close the gap.
Publishing pay gap data without acting on it is like diagnosing a problem and failing to treat it. That’s why we’ve published our latest briefing, From Data to Action, calling for mandatory gender pay gap action plans in Scotland’s public sector.
The gender pay gap: a persistent problem
The gender pay gap remains the most well-recognised indicator of inequality in Scotland’s labour market. The most recent Scottish data shows the pay gap sits at 8.3%, while the UK gender pay gap is 13.1%. when we look at part-time workers, Scotland’s pay gap increases to 23.7%, due to part-time work being concentrated in low-paid, undervalued jobs.
The pay gap is higher for marginalised women. There is limited Scottish data on ethnicity and disability pay gaps, but UK data paints a clear picture. Ethnicity pay gaps vary by ethnic group, however for almost all groups women from ethnic minority backgrounds face pay gaps of over 25%, when compared to white men, and disabled women face a pay gap of 23.5%, when compared to men who aren’t disabled.
This isn’t simply about unequal pay for the same or similar jobs. The pay gap reflects the structural barriers that shape women’s working lives. Women are concentrated in low-paid, undervalued jobs such as social care, childcare, and cleaning. They are more likely to work part-time or in insecure roles, often because of caring responsibilities. Occupational segregation channels men and women into different types of work, with men more likely to hold senior and higher-paid roles. These inequalities mean women are more likely to experience poverty, including in-work poverty, with clear links to child poverty.
Why the PSED needs reform
The Scottish-specific duties of the PSED are Scotland’s central equality regulations, setting out what public bodies must do to advance equality in their workforces and services.
For over a decade public bodies in Scotland have been required under the PSED to publish their gender pay gap. But reporting alone is not driving change. Our analysis shows that while most public bodies publish sizeable pay gaps, very few set out actions to address them.
The absence of mandatory action planning within the PSED is a critical weakness. Without it, gender pay gap data is published but sits unused, with no accountability for tackling the inequalities it highlights.
Scottish Government has committed to extend the duties to require public bodies to report on ethnicity and disability pay gaps. But, without action planning, this will simply replicate the same problems we’ve seen with gender pay gap reporting: data without action. Employers will continue to publish figures that highlight stark inequalities, but with no requirement to do anything to address them.
Mandatory gender pay gap action plans would ensure that public bodies identify the causes of their gaps and set out concrete, measurable steps to address them, reporting on progress over time. This would strengthen accountability, enable scrutiny, and most importantly, deliver change for women.
Scotland risks falling behind
The UK Government is moving ahead with plans to require mandatory gender pay gap action plans from large employers as part of the Employment Rights Bill. While these provisions do not apply to Scottish public bodies, they highlight the gulf that is opening up between Scotland and the rest of the UK.
Once regarded as a leader on equality, Scotland now risks being left behind, with women working in the public sector denied the same commitment to action as their counterparts elsewhere in Britain. The reputational risk to Scottish Government is clear, but the practical consequence of inaction is more important: without reform of the PSED, the gender pay gap in Scotland’s public sector will persist, undermining progress on women’s equality more broadly.
That’s why mandatory gender pay gap action plans are essential. Without them, Scotland will continue to collect statistics on inequality without ever addressing it.
A low-cost, high-impact reform
Mandatory action plans are a simple, low-cost intervention that would materially improve women’s economic outcomes and reduce poverty. They would also deliver against Scottish Government’s core priorities:
- Eradicating child poverty: addressing the pay gap is essential, given mothers and carers are more likely to be in low-paid, undervalued work.
- Fair Work: transparency alone is not enough; action planning would deliver the employer change Fair Work is intended to embed.
- Growing the economy: closing the pay gap would boost productivity by tackling women’s underemployment and pay inequality.
- Ensuring high quality and sustainable public services: the undervaluation of women’s care work is a key cause of the crisis in social care, driven by low pay and high turnover; action planning would help public bodies tackle this sustainably.
Time for action
The evidence is clear: without mandatory action plans, the gender pay gap will persist, and women and their families will continue to pay the price.
The Scottish Government must act now to strengthen the public sector equality duty and require public bodies to develop, publish, and report on gender pay gap action plans. Scotland cannot afford to fall further behind.
The Equally Safe at Work Community of Practice: Why working together matters
The Community of Practice peer support network had their first session back on 27th February 2025, and the focus of the day was understanding and embedding key elements of gender-sensitive practice. We were pleased to see many familiar faces, and also welcome new employers to the group.
Currently, 17 employers across the public and third sector are working towards the Equally Safe at Work accreditation and an additional 30 employers across Scotland are actively engaged in the Community of Practice peer learning network. Membership includes employers from across the third and public sector, including local governments, NHS boards, Police Scotland, Scottish Fire and Rescue Service, COSLA, and Scottish Government.
Since the first meeting of the Community of Practice, the peer learning network membership has grown significantly, which has offered new insight and fresh perspectives in discussions. Employers’ active participation in the meetings has enhanced its value, and the unique contributions from across sectors and organisations has resulted in employers taking away practical actions and ideas to test our in their own workplaces.
What is the Community of Practice?
The Community of Practice was first developed in 2023 to test out a new approach of shared learning by bringing together different sizes and types of organisations at different stages of their journey on gender equality and VAW. The aim was to find out whether participation in the group helped improve employment practices on gender equality. The evaluation of Equally Safe at Work found that the Community of Practice proved to be a useful mechanism for employers to build relationships, share information, and problem solve through common challenges.
The Community of Practice has further developed into a dedicated space for employers involved in the Equally Safe at Work accreditation programme to share best practice and learning to advance their gender equality work. Additionally, it works well to introduce employers to the programme, and to support them to get ready to work towards accreditation in the future.
Highlights from past Community of Practice meetings
Since its inception, the Community of Practice has continued to evolve, whilst ensuring that member feedback has guided the general direction of the network. Having an online platform dedicated to the Community of Practice was among the suggestions from employers on how to get more out of the group. This led to the development of a KHub group page where members can ask each other questions, easily share resources and access all Close the Gap and Equally Safe at Work materials to support their work.
By seeking member input, it also meant that they could vote on the topics to discuss at each meeting for the year. The meetings for the Community of Practice covered a variety of topics which included:
- Embedding an anti-racist approach in your gender equality practice;
- The role of leaders in tackling women’s workplace inequality;
- Workplace culture and the impact of negative workplace cultures, particularly on women’s employment experiences;
- Sexual harassment and employment law; and
- Successes and hopes for 2025.
At our most recent meeting, members shared that when thinking about gender equality and violence against women in their organisation, they would like to see better intersectional data in the future, reduced pay gaps, and improved understanding of what violence against women involves. From feedback, members noted that they left the session energised and eager to share their learnings with their own teams and organisations.
What’s worked
What has been vital to the success of the Community of Practice has been the participant engagement and continued commitment. It’s positive that so many new members have joined the group in the past year, but it’s been equally important that members have remained engaged throughout the programme of meetings for the Community of Practice. This high level of engagement has been encouraging for new members and has demonstrated the benefits of having a collaborative environment where shared learning is prioritised:
“Coming to these sessions is so positive. I am a new entrant to the programme, but these are invaluable for shared ideas and practice.” (Member of Community of Practice)
When the Community of Practice first began, it was expected that only Equally Safe at Work leads would be in attendance. Now, it has expanded out to staff across organisations who are interested in learning more about best practice, and about what other people are doing in the space of gender equality. This helps bring together a diverse range of views, experience, and expertise to the group as staff are from a variety of roles and sectors.
The desire to hear from employers about the different types of work they’re doing on gender equality has been evident, with members keen to know the specifics about how others were improving their reporting processes on VAW, how they disseminate resources effectively and increase engagement with hard-to-reach groups in surveys. Ultimately, the common goal of advancing gender equality and sharing ways of doing this has been reassuring for employers but especially for smaller organisations who may not have equalities teams or HR departments. This helps to foster a sense of community, despite organisational differences and structures.
Others found that there isn’t just one section of the Community of Practice that works well for them. The level of information, structure of the meetings, and length of time between meetings work effectively for them to remain engaged in the group. However, it is the overarching theme of being able to meet people from other organisations and learning from them that consistently comes through in all member’s feedback. The collective responsibility to share learning and advance gender equality is clear and appreciated, as multiple accredited employers delivered presentations throughout the year, sharing their experiences and valuable insight about what it’s like being part of the Equally Safe at Work journey and the vital work they’ve done as part of this.
How to get involved with Equally Safe at Work and the Community of Practice?
There are two ways to get involved and improve your gender- and VAW- sensitive practice. This includes, becoming an employer of choice through our Equally Safe at Work employer accreditation programme. Register your interest and start your journey now by completing the form here.
If you’re not quite ready to begin the process of accreditation but seek to improve your gender equality practice and gain access to this dynamic and supportive network, you can become a member of the Community of Practice. Here you will receive the latest updates about the Community of Practice, Equally Safe at Work and the wider work of Close the Gap including events and research. Join our Community of Practice peer learning network here.
Pension changes and the gendered impact: Accelerated action without consideration for women
For over a century, the International Women’s Day (IWD) has raised awareness of key issues relating to gender inequality and has been used as a platform to engage communities and promote positive action. This year, the IWD campaign’s theme ‘Accelerate Action’ is a call to bring about action to dismantle the systemic barriers women face and advance gender equality.
This year’s theme provides an opportunity to look further at what happens when action is taken without consideration of the gendered impacts. Systemic inequalities in women’s working lives contribute to the gender pay gap and persist into retirement which directly influences the gender pension gap. Women born in the 1950s and 60s have been affected by the change in state pension age, and many experienced hardship as a result of the insufficient notice provided of the change which has had a detrimental effect on their retirement plans and lives.
The WASPI Campaign
The Women Against State Pension Inequality (WASPI) campaign was formed in 2015 in response to pension reforms that significantly affected the women born in the 1950s and 60s. These reforms aimed to equalise the State Pension Age (SPA) between men and women, but the WASPI campaign highlights that the changes were implemented without adequate communication to those directly affected. As a result, many women faced significant financial and emotional distress due to the lack of notice and the abrupt changes to their retirement plans.
WASPI and similar groups don’t oppose the equalisation of the SPA itself, but their concern lies in how the changes were implemented. The accelerated timetable, combined with insufficient notice, left many women with little to no time to adjust. This failure to properly inform women about the reforms sparked widespread controversy about fairness and the responsibility of the government in ensuring that those impacted had enough time to prepare.
The timeline of SPA equalisation
The most controversial change came from the 2011 Pensions Act, which brought forward the SPA increase for women born in the 1950s, significantly reducing the time they had to plan for retirement. Many received this information too late, with some women having only a year’s notice—or none at all. According to the House of Commons Library, around 2.62 million women were affected by the 2011 changes by 2018.
The impact of accelerated changes: A gendered crisis
The increase in the State Pension age (SPA) has had a detrimental impact on older women’s finances, making it harder for them to manage their income and bills. The effects have been particularly harsh for those who’ve had to wait longer to receive their pension. Single women are more affected than those with a partner, and many have struggled to stretch their pension savings further, especially given that many already face low pay and poverty. This has taken a significant toll on their personal, financial, and mental wellbeing.
Gendered barriers in the labour market: A direct link to gender pension inequalities
The gendered barriers in the labour market, particularly around the provision of care have long-lasting effects on women’s financial security, including their State Pension. Women are four times more likely than men to give up work to care, often for multiple family members. As unpaid work isn’t valued or counted by existing economic measures, this means the State Pension system doesn’t fully reflect their contribution to the economy. Meanwhile, lower wages and the lack of affordable childcare create barriers that prevent women from earning as much as their male counterparts.
By the time women reach their late 50s, their average pension savings are less than two-thirds of men’s, with much of this gap caused by labour market inequalities like women’s prevalence in part-time, low-paid, undervalued jobs. These challenges are compounded for disabled women and women from racially minoritised groups.
Disabled women, for example, are more likely to be unemployed, and be funnelled into lower-paid roles. Racially minoritised women are more likely to be underemployed in terms of skills, and experience higher pay gaps. Their ability then to secure stable, well-paying jobs or advance in their careers is severely affected. These intersecting barriers exacerbate the financial inequality that these groups experience, leaving them with even fewer resources to build up adequate pension savings.
The unequal division of care work, women’s interrupted career histories due to caregiving, women losing out financially in divorce settlements, and the economic impact from the COVID-19 pandemic have all played a role in women’s lower lifetime pension contributions.
For women born in the 1950s and early 60s, these systemic issues, combined with the accelerated equalisation of the SPA, have created unique challenges. The equalisation of the SPA taking effect quicker than expected has essentially robbed many women the opportunity to build up a sufficient level of pension income, and worsened existing inequalities that have persisted throughout their lives.
Health and pension inequality: A growing concern
Although the SPA was increased in response to an ageing population, data from the National Records of Scotland shows life expectancy of age 65 stalled after 2012-2014, declined during Covid-19, and remains below pre-pandemic levels.
Nearly one in four ‘economically inactive’ people under SPA were out of work due to long-term sickness or disability. As disability becomes more prevalent with age, ill health remains a major concern for many women approaching SPA.
The rising SPA has forced women to stretch their pensions for longer periods. However, the proportion of life spent in good health has been decreasing rapidly for women compared to men. This limits women’s ability to remain in the workforce, as 1.5 million women are now ‘economically inactive’ due to long-term sickness, 200,000 more than men. By 2030, women in the most deprived areas are expected to experience over 16 years of ill health before reaching SPA.
The Department for Work and Pensions (DWP) reports that the ‘economic inactivity’ rate for women aged 50-64 was 31.3% in 2024, compared to 23.2% for men. For this cohort of women, being sick, injured or disabled continues to be the main reason why they’re not engaged in the labour market. Women in this group were twice as likely than men to report that caring responsibilities were also one of the main reasons for not looking for paid employment.
As women approach retirement, many may need to manage their health or take time off work. While working longer has benefits, both in terms of pension contributions and the social aspect, these are only enjoyed when individuals don’t feel they are forced to do so. The longstanding inequalities women face throughout their careers contribute to the gender pension gap, and with more women leaving the labour market early due to increasingly poor health, the financial impact is particularly acute for those women affected by the SPA equalisation.
The gender pension gap and growing inequalities
Women are more likely to rely on the State Pension in retirement but are also less likely to receive the full amount. Many women face career interruptions due to caregiving, leading to gaps in National Insurance contributions. Despite the increase in the SPA resulting in fewer women pensioners, the number of women living in pensioner poverty has actually risen. Women make up more than two-thirds of pensioners living in poverty, with single women particularly affected.
A recent study from NOW: Pensions revealed that, on average, a woman must work 19 years longer than a man to accumulate the same level of pension wealth . For young women, barriers to auto-enrolment, such as low earnings and age, exacerbate this gap. Currently, 100,000 more young women than young men do not qualify for auto-enrolment, and many women are not in pension schemes to begin with. Scottish Widows found that, of the 14.6 million women currently employed in the UK, 17% (2.5 million) do not qualify for auto-enrolment compared to just 8% of male employees.
A simplistic view that focuses on individual responsibility and choice does not recognise the gendered constraints around these. It also overlooks the many barriers women face in later life when it comes to employment, as well as the lifetime of inequalities that continue to affect them as they approach, and are well into, retirement.
The current context: Recommendations and government inaction
In response to the WASPI campaign, the Parliamentary and Health Service Ombudsman (PHSO) conducted an investigation into how the DWP handled communication about the SPA changes to affected women. The PHSO found that the DWP failed to adequately inform women about these changes and how they would affect their retirement plans. Although the PHSO was not able to examine the speed at which the changes were implemented, it was clear that this had a significant impact on women’s ability to save for retirement, even if they had been properly informed.
The PHSO’s investigation into the maladministration of pension changes has offered some hope for those affected. The 2021 report found that the DWP failed to adequately inform women about the changes, depriving them of the opportunity to adjust their retirement plans. Despite these findings, the UK government has refused to provide compensation for the women who were unfairly impacted. This refusal to provide fair compensation is merely a continuation of the injustices felt by this cohort of women, with decisions that continue to penalise them, and sustain gender inequality.
Close the Gap’s calls for action
Given the compounding factors that contribute to women’s pension inequality, particularly the severe impact on women born in the 1950s, it’s clear that significant action is needed. While prompt action is vital, sustained long-term commitment is necessary to drive lasting change and ensure the advancement of women’s equality in the workplace.
To promote gender equality and close the gender pension gap, we call on the UK government and employers to implement the following measures:
- Compensation for WASPI women: Provide fair compensation to help women secure financial stability in retirement.
- Affordable and accessible childcare: A vital step in reducing the gender pay and pension gaps, as outlined in our joint paper ‘A Childcare System for All’.
- Family Carer’s Top-Up: A policy that would see the government contribute to carers’ pensions at the National Living Wage level.
- Workplace pension reform: Address the barriers that prevent many women from qualifying for auto-enrolment.
- Government support for working women: Offer statutory paid leave for carers.
- Employers should take action to address the inequalities that disabled women and racially minoritised experience in accessing and progressing in the workplace.
- Employers should develop gender-sensitive employment practice that specifically tackles the barriers faced by disabled women and women with long-term health conditions.
These actions are key to advancing women’s equality in the workplace and securing a fairer retirement for women across the UK.
We are recruiting new trustees to our board!
Close the Gap is looking for new people to join our board of trustees.
About Close the Gap
It’s an exciting time to join Close the Gap, as we look to expand our impact and reach in driving action to end women’s labour market inequality and create real change in women’s lives.
Our Chair, Samantha Bedford, has shared her experience of working on the Close the Gap board:
“It’s a great way to use my knowledge, skills and experience and to give back.
It’s enabled me to become a better, more experienced trustee – seeing how others operate, the diversity of thought and the overall professionalism of the board.
I’ve learned so much about the issues and how to navigate public sector funding and influencing which continues to be fascinating.”
About you
Committed to women’s labour market equality, you’ll have the ability to think strategically and creatively, and to respond to the needs of the organisation. You’ll also be able to commit the time to fulfil the role of trustee and help us meet our strategic objectives.
We are strongly committed to equality, and recognise that diverse boards are more effective, and result in better governance practice. We would particularly welcome applications from racially minoritised people and disabled people, who are currently under-represented on our board.
We’re also especially interested in receiving applications from people that have knowledge and experience in equality and/or human rights, and fundraising.
How to apply
Applications must be submitted using our online application form which you can find at https://www.closethegap.org.uk/jobs/.
If you are unable to use an online application process, please contact us at info@closethegap.org.uk
The deadline for applications is Sunday 5th January 2025.
You will be notified by Friday 17th January 2025 if you have been selected for interview.
It is anticipated that the interviews will take place remotely during the week commencing Monday 27th January 2025.
New survey for disabled women in the Scottish workplace
Are you a disabled woman or a woman with a long-term health condition? We want to hear about your experiences of work in Scotland, to help improve women’s equality.
Close the Gap has been conducting a research project on disabled women’s experiences of employment in Scotland. Now, we’re launching a survey to gather more data to build a richer picture about disabled women’s working lives.
This survey builds on from our emerging findings, and will be part of wider research, with the aim that the inequalities women with disabilities and long-term health conditions face are better understood, and tackled, by policymakers and employers.
Take the survey here.
Who can take part?
The survey is open to disabled women and women with long-term health conditions who live in Scotland.
What do we want to know?
We want to hear about your experiences in the workplace on range of key areas including:
- recruitment
- access to training and development
- workplace culture
- discrimination
- violence against women
All responses will be anonymous. Findings from the survey will be analysed and used to inform the development of the final research report.
There’s also a chance to enter a prize draw to win a shopping voucher for your involvement. Prizes are 1 x £150 voucher, 2 x £75 vouchers, and 3 x £50 vouchers.
You can take the online survey here.
If you require an accessible Word version of the survey, please email info@closethegap.org.uk
The survey closes on Thursday 13 February 2025.