Following the publication of its consultation response on 25 March 2026, which revealed an emphatic 87% level of support, the government has confirmed plans to mandate ethnicity and disability pay gap reporting for large employers.
The measures will be introduced through the Equality (Race and Disability) Bill, marking a major expansion of the existing gender pay gap reporting framework under the Equality Act 2010 (EqA 2010).
While no firm implementation date has yet been announced, large employers should begin preparing now for substantial new data collection and reporting obligations.
Who will be required to report
The reporting duty will apply to employers with 250 or more employees, aligning with the threshold used for gender pay gap reporting. In scope will be:
- Private and voluntary sector employers across Great Britain
- Public sector bodies in England
- Certain public authorities operating across Great Britain in relation to non-devolved functions
What data employers will need to publish
The government has confirmed that, to minimise burden, ethnicity and disability pay gap reporting will follow the same structure and calculations as gender pay gap reporting. Employers will therefore be required to publish:
- Mean and median differences in hourly pay
- Pay quartile distributions
- Mean and median bonus pay gaps
- The percentage of employees receiving bonus pay
This consistency is intended to make the new regime easier to understand and embed alongside existing reporting processes.
Ethnicity pay gap reporting
For ethnicity pay gap reporting, employers will be required to publish a binary comparison between the pay of white employees (including “white other”) and the pay of employees from all other ethnic groups combined.
In addition, where sufficient data is available, employers must also report pay gap figures across five broad ethnic categories, in line with following classifications:
- White
- Asian or Asian British
- Black, Black British, Caribbean or African
- Mixed or multiple ethnic groups
- Other ethnic groups
To protect confidentiality, a minimum employee threshold will apply for each group. More granular reporting (for example across the full list of ethnic classifications) will not be mandatory, although employers will be encouraged to do so voluntarily where appropriate.
Disability pay gap reporting
Disability pay gap reporting will require a binary comparison between disabled and non-disabled employees, applying the definition of disability under section 6 EqA 2010.
The consultation explored whether reporting by type of impairment should be required. However, concerns about the sensitivity of the data, low declaration rates and the potential impact on employee trust led the government to reject this approach at this stage. The legislation will nevertheless be drafted to allow for more detailed reporting in the future if data quality and disclosure rates improve.
Workforce composition and context
In addition to pay gap figures, employers will also be required to publish workforce composition data, showing the overall breakdown of their workforce by ethnicity and disability, together with the percentage of employees who have not disclosed this information. The government has acknowledged that declaration rates are likely to be a challenge and has committed to producing guidance to help employers encourage employee disclosure and build trust, including examples of best practice.
Equality action plans
The reporting obligations will sit alongside wider reforms to equality action plans under section 78A EqA 2010. Employers will be permitted to publish equality action plans on a voluntary basis from April 2026, with mandatory publication expected from Spring 2027.
The government intends to expand the scope of these plans to include race and disability equality, requiring employers to explain the steps they are taking to address ethnicity and disability pay gaps and wider workplace inequalities. This will place a greater focus not only on transparency but also on demonstrable action.
Timing, enforcement and next steps
Ethnicity and disability pay gap reporting will use the same snapshot dates and publication deadlines as gender pay gap reporting. Enforcement will sit with the Equality and Human Rights Commission, which will have powers to investigate and take action for non-compliance.
Although no commencement date has yet been confirmed, the direction of travel is clear. Employers within scope should begin reviewing their HR systems and data, data protection arrangements and employee engagement strategies now to identify where they have incomplete ethnicity and disability data and implement a strategy to build those data sets to be as complete as possible. Once employers have the data sets, they need to identify any ethnicity and disability pay gaps and consider what steps they can take to reduce those gaps. Early preparation will be essential to ensure accurate reporting and to manage the legal, reputational and employee relations risks associated with the new regime.
If you would like assistance preparing for mandatory ethnicity and disability pay gap reporting, or reviewing your policies and processes in light of these reforms, please contact a member of our team: employment@wslaw.co.uk