Since 2021, Business Disability Forum has been conducting research on the impact of disability workforce and disability pay gap reporting among both employers and disabled people.
Here, we’ll examine key findings and considerations from the research, outlined in our recently published report ‘Towards meaningful disability workforce and pay gap reporting’.
A brief history of mandatory diversity reporting
First, let’s look at why mandatory disability pay gap reporting is relevant to HR right now.
The UK policy debate on mandatory diversity reporting started in December 2021 when the previous government published a consultation asking whether large employers should be required to report the number of disabled people they employ.
A couple of years later the Labour Party made a manifesto commitment to introduce disability pay gap reporting, but without mention of disability workforce reporting. Shortly after the Labour Party came into office in the summer of 2024, they introduced the Equality (Race and Disability) Bill, which is currently being debated in Parliament. This Bill would require large employers to report their disability and ethnicity pay gaps. On 18 March 2025, the Government published its consultation paper on disability pay gap reporting, which is open until 10 June 2025.
Against this backdrop, the Business Disability Forum has conducted a long-term qualitative research project to uncover the implications of these policy changes. Through running a series of focus groups, discussion groups, and indepth interviews, we’ve gathered feedback from employers and disabled employees.
The pressures of mandatory reporting
The first key finding from this study relates to the pressures of mandatory reporting.
With many employers increasingly reporting on their disability pay gap and disabled workforce, our research found organisations are worried they will be judged on their figures. Additionally, many employers in the study voiced concerns about the proposed legislation focusing on pay gap reporting without any mention of Government support to implement and work on getting good disability workforce data first.
Of those employers who were becoming happier with their year-on-year disability workforce reporting, the majority were collecting anonymous data.
But for an employer to conduct a disability pay gap analysis (and report on it), employees would need to define their disability status (and potentially their type of disability) next to their named HR and payroll records. We found both employers and disabled employees were reluctant to do this.
If we have the right processes in place, we rarely need to ask employees to disclose.
Disability pay gap reporting: Unintended (and harmful) consequences
This was not the only difficulty with mandatory reporting that we uncovered. We also found the following unintended consequences:
- Disabled employees often felt “bullied” or “harassed” by their employer’s internal campaigns to encourage them to share their disability status. This was not felt by employees alone. Employers also told us they fear they are “bullying employees for their data”.
- In industries where mental health conditions and work-related stress are most common, the prevalence of disability was often higher in reported figures. This could inadvertently reward poorly managed work-related ill health and stress.
- Some employers said they decline requested adjustments such as job carving or moving them to a less senior role (or reducing the seniority of responsibilities), because they know the impact this would have on the organisation’s disability pay gap.
- Employers who have increased job carving practices and invest in disability employment programmes for entry-level roles generally had wider disability pay gaps. Employers questioned what is valued more – a narrow pay gap, or increased labour market opportunities for disabled people.
- Employers who had improved and opened up their workplace adjustments and support provision to any employee to be more inclusive saw the number of employees sharing their disability fall. This is because these employers had effectively removed the need for employees to give a reason for why they were requesting to work differently. In one employer’s words, “If we have the right processes in place, we rarely need to ask employees to disclose”.
What’s the alternative to disability pay gap reporting?
These findings surprised us and led us to explore whether reporting the number of disabled people employed and the disability pay gap is the right data to collect. If it’s not, what should happen instead?
We asked the same question, separately, to both the employer group and the disabled employee group and they both gave us the same two-fold answer.
I can’t even get into the building.
1. Focus less on the numbers and more on adjustments
First, we should shift our focus away from disability disclosure and spend more time getting the basics of making adjustments right. The government’s figures state that only 23% of employers are making adjustments for their disabled staff, and our own research shows that just 45% of disabled employees have all needed adjustments in place. Employers we work with are constantly trying to improve their workplace adjustment service to ensure each employee has everything they need to be productive and do well at their job.
The disabled employee groups within our study were exasperated that the government was focusing on reportable numbers when, in one participant’s words, “I can’t even get into the building”.
Disabled employees told us loud and clear that the government should instead focus on ensuring employers make timely adjustments. This demand is of little surprise as our 2023 research shows 1 in 8 employees wait over a year to get adjustments.
Data collection on adjustments could be linked to this. For example, employers could track:
- How many employees work with adjustments?
- Do employees have all the adjustments they need?
- How long did it take to get these adjustments?
2. Collect data on barriers faced by employees
Second, both the employer and disabled employee groups recommended that data be collected on the barriers employees experience. Whereas the above workplace adjustments are individual and specific, barrier-specific data allows employers to constantly work on identifying, removing, and anticipating systemic barriers in their organisations.
Examples of these types of barriers include: struggling with an element of the workplace’s physical environment (such as lighting), communication issues and difficulties with the IT system. This idea of collecting data ‘by barrier’ has gained a lot of interest from HR and diversity leaders, and so we will be developing this recommendation with our Disability Data Monitoring Working Group over the next few months.
Beyond disability pay gap reporting
The Government needs to make the labour market an inclusive and barrier-free place. Whether mandatory workforce and disability pay gap reporting will do that is yet to be evidenced.
For HR leaders striving to embed more meaningful practices to foster disability inclusion, our research shows the importance of going beyond reporting the numbers. Focus on assessing and refining your approach to workplace adjustments, and consider how to better spot and remove the barriers holding your people back.
