Hi Catherine

When was the acquisition? If it was after 4 April 2022 (assuming you are private sector), if you were still under 250 before this date, you won't need to report.

If it was before April 2022, I would keep an eye on forthcoming updates from the Government before committing a lot of time to this. Whilst not confirmed, the Govt appears to be considering raising the company size threshold for gender pay reporting to companies sized 500+.

Regarding who's to be included in report, if your UK h/c is 180, with the remainder of the 400 being overseas, assuming these other employees are employed by an entity in another country (and subject to the legislation/payroll of that country), you wouldn't need to include all 400, and wouldn't need to gender pay report.

From the Govt site

"As a general rule, an employee working overseas will be within the scope of the regulations if they can bring a claim to an Employment Tribunal under the Equality Act 2010. This will depend on whether the employment relationship suggests a stronger connection to Great Britain and British employment law, than to the law of any other country.

Indications that someone should be treated as an employee when establishing your headcount include:

having a contract subject to GB legislation
continuing to have their home in GB, and
having the UK tax legislation apply to their employment."

Assuming you don't have 220 GB ex-pats working internationally, your overseas employees don't count

Joe

In reply to Joe :

Thanks Joe, this is really helpful! Much appreciated

Are you referring to GB as Great Britain, and NI as Northern Ireland? I wasn't aware that the law on gender pay gap reporting was different for Northern Ireland staff, unless the employer entity is separate and not part of a legitimate company grouping.