Ethnicity and disability pay gap reporting: what employers need to know

• 6 May 2026
• News
• Employment

The government has confirmed that it will introduce mandatory ethnicity and disability pay gap reporting for employers with 250 or more employees. We do not yet have an implementation timeline.

New requirements will be streamlined with gender pay gap reporting with the same six calculations and the same snapshot and reporting dates. Besides reporting on pay gap figures, employers will be required to report on the overall composition of their workforce, as well as the percentage of employees who have declined to declare their disability status or ethnicity. They will also need to provide action plans to tackle pay gaps.

Ethnicity data should be gathered using the GSS harmonised standard used in the 2021 census, with ethnicity groups aggregated into five broad groups (White, Asian/Asian British, Black/Black British/Caribbean/African, Mixed/Multiple, Other). Comparisons need to be made between the White group and all other groups and, data permitting, individually between each group.

Disability data will use the Equality Act 2010 definition, and comparisons will be binary between disabled and non-disabled employees.

Data collection will need to offer employees a ‘prefer not to say’ option, and reporting requirements will be suspended to preserve anonymity where the number of employees in a group does not meet a certain threshold (likely 10, though this remains to be confirmed).

The most important step in-scope employers can take now is to builda strong data collection framework. Employers must (where not already done) put the right, data protection-compliant systems in place, but should also work to build employee engagement to secure high response rates. That is a question of building trust in the process, but also of employee education. In the case of disability reporting, for example, the Equality Act definition is technical and very broad, and is likely to capture a number of employees who do not self-identify as disabled – including, for example, often high-performing neuro-divergent staff. Leading thoughtful discussions with employees about how the categories are drawn and the reasons for reporting may well significantly improve your data. On this point, you should of course be alert to the fact that, where employees disclose a disability to you outside the anonymised data gathering process, that will trigger additional duties.

Once you have robust data collection processes in place, you may wish to run trial calculations and start putting together an action plan to address gaps. The team can support you with this work.

Please reach out to the team if you would like to discuss the new reporting requirements and how they affect you in more detail.