Mandatory ethnicity and disability pay gap reporting is no longer a distant policy conversation. It is coming, potentially as early as next spring, and for many employers that will arrive sooner than they expect. Following years of debate, pilots and voluntary frameworks, the UK government has now confirmed its intention to require large organisations to publish ethnicity and disability pay gap data, broadly mirroring the gender pay gap regime. On paper, this might feel familiar. In practice, it represents a step change. Not because the calculations are new, but because the data behind them is harder to collect, more sensitive to handle, and far more dependent on trust.
What do we know so far? Employers with 250 or more employees will be expected to report using the same core measures used for gender pay gap reporting: mean and median pay gaps, bonus gaps, bonus participation, and pay quartiles, based on a defined snapshot date. Organisations will also need to publish workforce composition data, disclose non‑response rates, and set out narrative explanations and action plans. In other words, this is not just about numbers on a spreadsheet. It’s about what those numbers say, what they do not say, and how credibly organisations can explain both.
Crucially, while reporting will be mandatory, disclosure by individuals will not be. Ethnicity and disability data relies on people choosing to share deeply personal information, often shaped by lived experience, workplace culture, and confidence that doing so will lead to positive change rather than unintended consequences. That creates a gap between what the legislation requires and what many organisations currently have. Being “up to scratch” on inclusion data, then, is not simply a compliance exercise. It is a test of data foundations, governance, and trust, long before the first reporting deadline appears in the diary.
The data dilemma
In contrast, ethnicity and disability pay gap reporting has a very different starting point from gender pay gap reporting. UK legislation around this is to report on binary sex recorded at birth - information that already exists on right‑to‑work documentation. The data is there, immediately available to employers with no need to request, and no decision around disclosure. For ethnicity and disability, that safety net does not exist. Employers are entirely reliant on people choosing to share.
The scale of the challenge is clear. Disability disclosure rates in the UK workforce are widely believed to sit at around 25%, while ethnicity disclosure is closer to 65%. That means many organisations are attempting to produce meaningful, reportable insights from datasets that are partial, uneven and, in some cases, statistically fragile. The risk is obvious. Gaps may be masked or exaggerated, trends may be misread, and confidence in the data, both internally and externally, can quickly erode.
But low disclosure is not a technical failure. It’s a human signal. If people are reluctant to share, it’s rarely because they don’t understand the question. More often, it reflects uncertainty about how the data will be used, who will see it, and whether it will lead to positive change or unintended consequences. For disabled employees and racially minoritised groups in particular, disclosure decisions are shaped by trust, past experience, and perceptions of safety at work.
This is where many organisations get stuck. They focus on the mechanics of reporting before they have truly understood the reasons behind non‑disclosure. Yet without that understanding, efforts to improve data quality risk feeling transactional, performative, or worse, coercive. And that is a problem no amount of spreadsheet cleansing can fix.
We are people, not percentages
When organisations talk about inclusion data, it’s easy for the conversation to slide into percentages, targets and response rates. But people do not experience data that way. They experience it personally, emotionally, and often cautiously.
For many people, sharing information about disability or ethnicity is not a neutral act. It’s shaped by questions that rarely make it into a data collection notice. What will this data be used for? Who will see it? Will it change anything? And, perhaps most importantly, could it be used against me, now or in the future?
For disabled employees, disclosure decisions are often shaped by past experiences of stigma, disbelief, or adjustments that were promised but never delivered. For racially minoritised employees, there may be concerns about stereotyping, tokenism, or being reduced to a data point rather than recognised as an individual.
Research shows, people are more willing to share data when they believe it serves a clear social purpose and when safeguards against harm are visible and credible. In workplace terms, that means inclusion data cannot simply be extracted and reported. It has to be earned.
This is where the shift in mindset matters. If organisations treat ethnicity and disability data as a compliance requirement first and a human issue second, disclosure rates are unlikely to improve. But when people see evidence that data leads to fairer decisions, better policies, and tangible change, sharing starts to feel less like a leap of faith and more like a collective investment.
Inclusion data, then, is not about getting people to tick boxes. It is about recognising that behind every percentage is a person making a judgement call about trust.
Trust leads to truth
If low disclosure is the problem, trust is the only sustainable solution. But there is no universal formula for building it. What works in one organisation may fall flat in another, because trust is shaped by culture, history, leadership behaviour, and lived experience. In other words, this is not a toolkit exercise. It’s a credibility exercise.
There are, however, some consistent foundations. One of the most important is being genuinely clear about what inclusion data will be used for and how it will be managed. Words alone are not enough - trust is built through action. When organisations can show how data led to decisions, and how those decisions benefited the workforce, inclusion feels purposeful rather than performative.
Gender pay gap reporting illustrates this. The most credible stories are not about the metric itself, but what drove the change: clearer progression pathways, fairer access to development, stronger support for flexible working, and greater accountability for managers.
The same applies beyond pay. Where else has insight shaped recruitment, retention, or progression, and for whom? Data earns legitimacy when people can see its impact on real outcomes.
And if progress is still underway, say so. Honesty about where you are and where you want to go often builds more trust than a polished success story. Most employees are looking for intent, learning, and transparency - not perfection.
Stories from the workforce, shared with care, can help here. They humanise the data, showing how insight becomes experience and experience drives change.
If inclusion data is the destination, trust is the route. Without it, organisations may report, but never truly understand the numbers.
You are not alone
Navigating ethnicity and disability pay gap reporting can feel complex, high stakes, and intensely personal - but you don’t have to do it alone.
An external inclusion partner can bring clarity, challenge, and confidence, helping you strengthen data foundations, build trust with your workforce, and turn insight into meaningful action.
Our talent advisory team works alongside organisations to improve disclosure, shape credible narratives, embed inclusion into talent strategies, and help leaders ask better questions of their data.
If you’re starting this journey, or reassessing where you are, a confidential conversation can be a powerful first step. Get in touch with our experts today.
