Mandatory ethnicity and disability pay gap reporting for larger employers

The consultation by the government seeking views on how to introduce mandatory ethnicity and disability pay gap reporting for large employers is due to close on 10th June 2025. At the moment, the government is considering a similar framework that is used for gender pay gap reporting for larger employers. 

Who are these larger employers?

These would be employers with 250 or more employees.

 What would they report on?

These employers would have to report on mean and median differences in pay in the same way as gender pay gap reporting. 

In addition, the government is looking at mandatory reporting on the overall breakdown of the larger employer’s workforce by ethnicity and disability, as well as the percentage of employees who do not disclose their personal data on their ethnicity and disability. 

There is also a proposal that employers should have to produce action plans for ethnicity and disability reporting which is aimed to assist employers to explain reasons behind any pay gaps and how they intend to close these gaps.

How would this data be collected?

The current thinking is that employees will be asked to report on their own ethnicity with the option to “prefer not to say”.

For disability, the proposal is for a binary approach of only reporting differences between disabled and non-disabled employees.

Who would enforce these rights?

The Equality and Human Rights Commission would be responsible for enforcing rights in the same way as gender pay gap reporting.  

What should you do now?

As the consultation will shape the government’s next steps on developing and drafting the legislation in the form of the Equality (Race and Disability) Bill, then employers who this will impact should include their views on this now, so that they can be considered. 

Please see the link below for the consultation:

Equality (Race and Disability) Bill: mandatory ethnicity and disability pay gap reporting – GOV.UK

The contents of this article is a general guide only at the date of publication. It is not comprehensive, and it does not constitute legal advice. Specific legal advice should be sought in relation to the particular facts of a given situation.