What works? Collecting and managing disability data
Large UK employers face imminent mandatory disability pay gap reporting under a forthcoming Equality (Race and Disability) Bill, turning voluntary data practices into a compliance necessity with potential legal and reputational costs for inaction.
Key takeaways
- •The draft Equality (Race and Disability) Bill, expected to be published following 2025 consultations, will require employers with 250+ employees to publicly report disability pay gaps, mirroring gender pay gap rules and necessitating accurate disability data collection.
- •Poor or absent disability data leaves employers exposed to equal pay claims, enforcement by regulators, and failure to demonstrate progress on closing the persistent disability employment gap, currently around 30 percentage points.
- •Tensions exist between encouraging voluntary disclosure for inclusion benefits and privacy concerns that suppress response rates, while over-reliance on self-identification risks incomplete or biased datasets without trust-building measures.
Rising Pressure on Disability Data
The UK labour market continues to show a stark disability employment gap, with disabled people of working age employed at roughly 53% compared to over 82% for non-disabled people as of mid-2025. This disparity persists despite long-standing protections under the Equality Act 2010, which prohibits discrimination and requires reasonable adjustments but does not mandate systematic disability monitoring or pay gap disclosure.
Momentum for change accelerated under the current government. A consultation on mandatory ethnicity and disability pay gap reporting for employers with 250 or more staff closed in June 2025, proposing frameworks similar to gender pay gap obligations, including publication deadlines and contextual measures. The anticipated draft Equality (Race and Disability) Bill would extend equal pay rights explicitly to disability and race, ban outsourcing as a means to evade pay equity, and enforce corrective actions on identified gaps.
Parallel reforms to the Disability Confident scheme, with a delivery plan running through December 2026, emphasise enhanced transparency via robust data collection and impact measurement. While voluntary, the revamped scheme aims for greater accountability, aligning with broader ambitions to reduce economic inactivity and boost inclusive employment.
Concrete stakes include regulatory scrutiny and potential litigation: without solid data, employers cannot benchmark pay equity, respond to claims, or evidence compliance. Costs arise from equal pay liabilities, reputational damage, and recruitment/retention challenges amid rising disability prevalence—now affecting about 25% of the UK population. Non-obvious trade-offs involve balancing data utility against low disclosure rates due to mistrust or stigma, where forcing questions can deter responses while sensitive, anonymous approaches improve accuracy but complicate verification.
The timing reflects wider policy pushes to make work pay and reduce inequality, but implementation risks uneven enforcement and varying employer readiness, particularly where HR systems lag in capturing reliable, consistent disability information.
Sources
- https://businessdisabilityforum.org.uk/event/what-works-collecting-and-managing-disability-data/
- https://www.gov.uk/government/publications/disability-confident-reform-delivery-plan-december-2025-to-december-2026/disability-confident-reform-delivery-plan-for-december-2025-to-december-2026
- https://www.doyleclayton.co.uk/resources/news/employment-law-guide-2026-draft-equality-race-and-disability-bill
- https://www.cipd.org/uk/views-and-insights/thought-leadership/insight/employment-law-changes-januarry-2026
- https://businessdisabilityforum.org.uk/resource/disability-workforce-reporting
- https://www.gov.uk/government/statistics/the-employment-of-disabled-people-2025/the-employment-of-disabled-people-2025
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