On 25 March 2026, the government published its response to the consultation on mandatory ethnicity and disability pay gap reporting. The consultation received 857 responses and our submission can be found here.
The findings show strong support for action.
- 87% of respondents agreed that large businesses should report their ethnicity pay gaps
- 73% of respondents agreed that employers should report ethnicity pay gap measures using binary classifications at minimum
- 81% of respondents agreed that ethnicity pay gap reports should be accompanied by an action plan
- 77% of respondents agreed that employers should collect ethnicity data using the GSS harmonised standards for ethnicity
The consultation also explored how closely the reporting framework should align with gender pay gap reporting. There was clear support for consistency, including the use of a similar methodology and the same snapshot date.
In our response, we set out three key recommendations:
- Mandate the binary reporting to compare the White Group against all other categories, rather than the stated preference of White British against all other groups.
- Disaggregated reporting should be applied against the five ethnic groups as defined by the ONS, rather than further disaggregation when minimum thresholds are reached.
- Ensure guidance on disaggregation also presents businesses with the option of reporting a binary gap and a separate gap for a specific group (i.e. a black pay gap).
All three recommendations have been adopted as the government’s preferred approach. The response states that these decisions are informed by consultation feedback and ongoing stakeholder engagement and are intended to ensure reporting is both straightforward for businesses and capable of generating meaningful data to drive action on inequality.
As the draft bill progresses, we will continue to ensure that the leadership shown by Change the Race Ratio members on voluntary reporting, and the lessons learned, help shape the government’s approach to mandatory ethnicity pay gap reporting.
Responding to the publication, Change the Race Ratio CEO Richard DeNetto said:
“We welcome the publication of the government’s response and are pleased to see that our members’ experience of voluntary reporting is strongly reflected.
Change the Race Ratio has long called for organisations with more than 250 employees to report their ethnicity pay gap. Encouragingly, around 70% of our members are already doing so voluntarily.
Over the past five years, our members have worked together to share best practice on data collection and reporting. They have made strong progress in increasing disclosure rates, publishing their pay gaps, and, importantly, taking action grounded in data and evidence.
We encourage other businesses to begin collecting this data so they can better understand the makeup of their workforce and identify where representation gaps exist.
We look forward to continuing to ensure our members’ experience is reflected as the draft bill develops.”
