Get in touch 0117 325 0526
Get in touch 0117 325 0526
In July 2024, the Government used the King’s Speech to announce its intention to bring forward the Equality (Race and Disability) Bill, introducing a requirement for large employers (those with 250 or more employees) to report on ethnicity and disability pay gaps.
What’s new?
The Government published a consultation on 18 March 2025 asking for views on how the reporting requirement should be implemented. The consultation runs until 10 June 2025 so do have your say!
The Government proposes to use the same set of pay gap measures for ethnicity and disability as are currently in place for gender pay gap reporting – including the same snapshot and reporting dates. The Equality and Human Rights Commission (EHRC) would enforce the new pay gap reporting frameworks as it currently does for gender pay gap reporting.
Employers would need to report on six pay-related measures, including mean and median hourly pay, pay quartiles, mean and median bonus pay, and bonus participation rates.
Employers would also need to provide data relating to the:
The plan is for employees to self-report their ethnicity and disability status, with the option to opt out.
The Government proposes setting a minimum threshold of 10 employees in any ethnic group for ethnicity pay gap reporting. To meet this requirement, employers may need to combine certain ethnic groups. For organisations with smaller employee numbers across different ethnicities, a ‘binary classification’ option is suggested, allowing them to report pay gaps by comparing two broad categories – for example, white British employees versus ethnic minority employees.
For disability pay gap reporting, the Government recommends a fully binary approach, comparing the pay of disabled employees to non-disabled employees. Similarly, a minimum of 10 employees in each group would be required for the data to be reported. The Equality Act 2010 definition of disability will apply.
The consultation also seeks views on whether employers should be required to publish action plans explaining any identified pay gaps and the steps being taken to address them.
For public sector bodies, additional requirements are being considered including ethnicity pay differences by grade or salary band and data on recruitment, retention and progression by ethnicity. The consultation also seeks views on whether these additional requirements should be extended to disability.
If you’d like assistance with Ethnicity or Gender Pay Gap reporting – or indeed any aspect of Pay and Reward in your organisation, we can help. Please get in touch; enquiries@menzieslaw.co.uk / 0117 325 0526
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