Q&A - ethnicity and disability pay gap reporting

Q&A - ethnicity and disability pay gap reporting

Q. I understand that the government plans to introduce mandatory ethnicity and disability pay gap reporting. Will this apply to small employers?

A. The government is proposing that the upcoming Equality (Race and Disability) Bill, expected to be published later in 2025, will make it mandatory for employers to report on their ethnicity and disability pay gaps. It is currently seeking views on the measures it proposes to include in the Bill. However, the reporting requirements will only apply to "large employers", i.e. those with 250 or more employees.

Tip. Regardless of workforce numbers, if you are to avoid equal pay or discrimination claims, you should still be taking steps to identify any pay differentials amongst your staff, including establishing the causes of any significant pay differences, assessing whether these can be justified on grounds unrelated to sex, race, etc. and establishing a plan to address any differences that can't be justified on non-discriminatory grounds.

Mandatory ethnicity and disability pay gap reporting will only apply to large employers with 250 or more employees. Smaller employers will be exempt from the requirements.