The government’s response to the consultation on mandatory ethnicity and disability pay gap reporting landed today. From this point, we can expect large employers to report pay gaps, workforce composition, declaration rates, and action plans for both characteristics. The framework mirrors gender pay gap reporting, which at least means employers already have the infrastructure.

This is important and something that should have been in place way before now. Most ethnic minority groups earn less on average than their White British peers, and the national disability pay gap stood at 12.7% in 2023. Those figures are not controversial. What has been missing is systematic, comparable data at an organisational level that makes the gap visible and attributable.

Transparency is not an intervention but is the precondition for one. Gender pay gap reporting will not close the gender pay gap on its own, and there is no reason to expect ethnicity or disability reporting to work differently. But it changed what organisations could no longer credibly ignore and the same logic applies here.

The action plan requirement is the more significant commitment. Data without a response is performance, and mandatory action plans, aligned with existing gender pay gap obligations and eventually consolidated into a single equality plan, create at least a structural expectation that employers will respond rather than simply disclose.

The hard problems remain unresolved. Declaration rates will be low in many organisations, particularly for disability, where the Equality Act definition sits uneasily with how many people understand their own experience. Intersectional data is encouraged but not required. The minimum employee threshold for each reported group is still being worked out.

None of that is a reason to oppose the policy. It is a reason to implement it seriously rather than treat it as a compliance exercise. The organisations that will gain most from this are those that use the data to interrogate their own systems rather than manage their public figures.

The floor has been raised. What happens above it is still a choice.