Equality (Race and Disability) Bill: mandatory ethnicity and disability pay gap reporting

There were 857 responses to this consultation. This included:

• 614 responses to the Citizen Space survey
• 243 responses that were submitted in a different way, such as by email or post 

The government response provides a summary of the findings and sets out further details on the proposed approach towards mandatory ethnicity and disability pay gap reporting. It includes indicative clauses that have been developed to illustrate how the legislation may work in practice. 

Alongside this response, we have published:

• the independent analysis of the consultation responses, produced by Explain Market Research Ltd
• the regulatory impact assessment which outlines the expected costs and benefits of the proposed measures

There were high levels of support for the proposals set out in consultation. The majority of respondents agreed with all proposals, with over 70% net levels of agreement (‘strongly agreed’ and ‘somewhat agreed’) for each question. 

In response, we intend to implement the following proposals: 

• align ethnicity and disability pay gap reporting with the existing framework for mandatory gender pay gap reporting – that is, apply mandatory reporting to employers with 250 or more employees, use the same geographic scope, require the same 6 calculations, share the same ‘snapshot’ dates for collecting pay information and statutory reporting dates, require employers to upload their ethnicity and disability pay gap data to an online reporting platform, and be subject to the same enforcement mechanisms
• require employers to report on the overall composition of their workforce by ethnicity and disability (also referred to as ‘workforce reporting’) and the proportion of their employees who have declared their ethnicity and disability data
• require employers to take actions to address any ethnicity and disability pay gaps, in line with the plans being taken forward to introduce equality action plans on gender and the menopause

However, we will not be mandating the additional reporting requirements for public bodies as proposed in the consultation. These would have required employers to submit more detailed pay gap comparisons by grade or salary band, and information on recruitment, retention and progression. We will instead encourage this voluntarily through guidance.

The manifesto committed to introducing mandatory ethnicity and disability pay gap reporting for large employers (those with 250 or more employees) and making the right to equal pay effective for people from ethnic minorities and disabled people.

The Office for Equality and Opportunity (OEO) ran a public consultation on ethnicity and disability pay gap reporting in 2025. The consultation closed on 10 June 2025.