The UK government has confirmed that it will legislate to require large employers to report their ethnicity and disability pay gaps, publishing its response to a public consultation that ran from 18 March to 10 June 2025.
The reporting duty will apply to employers with 250 or more employees, aligning with the threshold already used for gender pay gap reporting, which has been mandatory since 2017. Smaller employers will not be required to report but will be encouraged to do so voluntarily, supported by government guidance.
The new requirement is expected to be introduced through the Equality (Race and Disability) Bill, first announced in the King's Speech in July 2024. Rather than publishing a full draft Bill, the government's March 2026 response included indicative legislative clauses, along with a regulatory impact assessment. The detailed reporting requirements — including calculation methods and any minimum thresholds for reporting on smaller sub-groups within a workforce — will be set out later in secondary legislation. The government has not yet committed to a specific implementation timeline.
The response confirmed that employers will be expected to use standardised mean and median pay gap calculations, alongside additional reporting on workforce composition and employee declaration rates. The government also said it would produce guidance on improving declaration rates, since ethnicity and disability data — unlike gender — relies on employees voluntarily disclosing this information.
Once the ethnicity, disability and existing gender pay gap requirements are all in force, employers will be able to produce a single combined equality action plan, the government said. The Equality and Human Rights Commission, which enforces the gender pay gap regime, is expected to use the same enforcement mechanisms for the new reporting duty.
The Equality and Human Rights Commission has separately called for organisations to be given adequate time to build trust with employees before mandatory data collection begins, saying meaningful declaration rates cannot be achieved quickly.