Business Disability Forum began conducting research in 2021 on the impact of disability reporting and the disability pay gap among employers and disabled people.
We’ll look at the key findings from our recent report, Towards Meaningful Disability Workforce and Pay Gap Reporting.
The history of mandatory diversity reporting
Let’s first examine why disability pay gap reporting must be mandatory for HR.
The UK’s policy debate over mandatory diversity reporting began in December 2021, when the former government published a questionnaire asking if large employers should have to report how many disabled employees they employ.
Two years later, the Labour Party announced in its manifesto that it would introduce a disability pay gap report. However, they did not mention disability workforce reporting. The Equality (Race and Disability) Bill is being debated by Parliament, shortly after the Labour Party took office in summer 2024. The bill would require that large employers report their disability pay gaps and ethnicity pay gap. The Government will publish its consultation paper regarding disability pay gaps on 18 March 2025. It is open to the public until 10 June 2025.
In this context, the Business Disability Forum conducted a qualitative research project over a period of time to discover the implications of the policy changes. We’ve collected feedback from employers and employees with disabilities through a series focus groups, discussion group and in-depth interviews.
Pressures from mandatory reporting
This study’s first major finding relates to mandatory reporting.
Our research shows that organisations worry about being judged based on their numbers. Many employers are reporting their disability pay gaps and their disabled workforce. Many employers expressed concerns in the study about proposed legislation that focuses on reporting pay gaps without any mention of government support for implementation and working on getting good data on disability workforce first.
The majority of employers who are happy with their disability workforce reporting year-on-year collect anonymous data.
To enable an employer to perform a disability gap analysis and report on the results, employees must define their disability status. (And possibly their type of disabilities) Next to their HR and payroll records. Both employers and disabled workers were reluctant to make this change.
We rarely ask our employees to divulge their information if we have the correct processes in place.
Reporting on disability pay gaps: unintended (and harmful consequences)
We also found the following unintended consequences: Unintended consequences were also discovered.
- Employees with disabilities often feel “bullied” or harassed by internal campaigns that encourage them to disclose their disability status. Employees were not the only ones who felt this. Employers told us that they also fear “bullying” employees to get their data.
- The prevalence of disability in industries with the highest rates of mental health problems and stress at work was higher than reported. Inadvertently, this could reward poor management of work-related stress and ill health.
- Some employers have said that they refuse to make requested adjustments, such as moving someone into a lower-level role or reducing their seniority (or reducing their responsibilities), knowing the impact it would have on an organisation’s pay gap for disabled employees.
- Employers that have invested in disability employment programs for entry-level positions and increased their job carving practices had larger disability pay gaps. Employers asked themselves if they valued a smaller pay gap or more opportunities on the labour market for disabled people.
- The number of employees who shared their disability dropped for employers that improved their workplace adjustment and support provisions and made them more inclusive. These employers have removed the requirement for employees to explain why they wanted to work differently. According to one employer, “if we have the correct processes in place, then we rarely need employees to disclose”.
What is the alternative to reporting disability pay gaps?
We were surprised by these findings and wondered if reporting the number disabled people employed, and the disability wage gap was the correct data to collect. What should be done instead if it’s not?
Both the employer group as well as the disabled employee group gave us the exact same answer.
I cannot even enter the building.
1. Focus on adjustments and less on numbers
We should first shift our focus from disability disclosure to the basics of making accommodations. According to government figures, only 23% employers make adjustments for their disabled employees. Our own research also shows that only 45% of disabled workers have all the necessary adjustments. Our employers are always working to improve the workplace adjustment services they provide to their employees. This is to ensure that each employee gets everything needed to be productive at work and to do well.
Our study found that disabled employees were frustrated by the government’s focus on numbers. As one participant put it, “I cannot even enter the building”.
The disabled employees we spoke to were clear in their message that the government should focus instead on ensuring that employers make timelyadjustments. It is not surprising that this demand has been made, as our research 2023 shows that 1 in 8 employees have waited over a full year for adjustments.
This could be used to link data collection about adjustments. Employers could, for example:
- How many employees are involved in adjustments?
- Are employees getting all the adjustments that they need?
- How long did you take to make these adjustments?
2. Employee barriers to success: Collecting data
Both the employer groups and the disabled employee groups suggested that data be collected about the barriersexperienced by employees. While the workplace adjustments above are specific and individual, barrier-specific information allows employers to work constantly on identifying, removing and anticipating systemic obstacles in their organisation.
These barriers can include communication problems, IT issues and problems with the physical environment of the workplace (such as lighting). The idea of collecting data “by barrier” has been a popular one among HR and diversity leaders. We will develop this recommendation over the next few month with our Disability Data Monitoring Working Group.
Disability pay gap reporting: beyond the standard report
The government must make the labor market inclusive and free of barriers. It is still unclear whether mandatory reporting of the disability and workforce pay gaps will achieve this.
Our research shows that HR leaders who want to implement more meaningful practices for disability inclusion must go beyond simply reporting numbers. Assess and refine your approach to workplace modifications and think about how you can better identify and remove barriers that are holding back your employees.
