
The UK government’s equality (race and disability) bill includes a new requirement for companies with 250 staff or more to report their ethnicity and disability pay gaps. While this proposal aims to highlight unfair pay discrepancies, such reporting can exacerbate some of the challenges disabled employees face, according to a new report from Business Disability Forum (BDF).
BDF surveyed 64 employers and 64 disabled employees for its report, Towards meaningful disability workforce and pay gap reporting – the challenges and unintended consequences. It claims pay-gap reporting that focuses solely on the numbers can “inadvertently incentivise” employers to make some opportunities in the workplace less inclusive.
The research found that businesses can sometimes decline reasonable adjustments for disabled employees – such as reduced hours or job-share arrangements – to avoid widening the company’s disability pay gap.
“At first glance, mandatory disability reporting seems simple and the right thing to do. However, our research shows that reporting on numbers alone will not achieve greater workplace inclusion for disabled people,” says Angela Matthews, BDF’s director of public policy. “Worse still, such reporting may even come at the expense of inclusion. Both employers and disabled employees have expressed concerns about the unintended consequences of the current proposals.”
Not just a numbers game
Overly simplistic reporting methods may indicate that organisations with the highest percentage of disabled employees or the narrowest pay gap are the most inclusive. This could create perverse incentives, the report warns. Industries where the prevalence of workplace stress and mental ill-health are highest may appear more inclusive as a result.
BDF also found that fewer workers disclose disabilities if their employer offers proactive support and workplace adjustments.
Disabled employees therefore were less supportive of mandatory pay-gap reporting than employers. Some of those surveyed said they fear being forced to disclose a disability, while others said that a focus on reporting could leave those who are undiagnosed to be overlooked.
Helen Crossland, partner and co-head of employment law at Seddons, says: “Employees are not compelled to disclose their personal details, and many opt to not complete equal-opportunities monitoring forms. As to disabilities, individuals may prefer to not reveal mental or physical health conditions, or may neglect to formally record changes in their personal fitness in the course of their employment.”
Companies must be willing to make adjustments based on the needs of staff, regardless of whether or not they have formally disclosed a disability. Only one in 10 disabled employees surveyed by BDF said securing the appropriate workplace adjustments was easy. One in eight had to wait more than a year for the adjustments to be made.
Although the disability pay gap in the UK remains high – disabled employees are, on average, paid 12.7% less per hour than non-disabled staff – support for those with disabilities is also lacking in the workplace.
Measurement will help to highlight this issue but focusing on the numbers alone is not enough. Employers must also increase support and offer workplace adjustments proactively if they are to be truly inclusive of workers with disabilities.
How can disability pay-gap reporting be improved?
These are the Business Disability Forum’s recommendations.
Basing pay-gap figures on hourly wage, rather than annual salary, will help firms to more accurately assess the overall gap, as figures will not be skewed by those working part time or as part of a job share.
Recording hours-worked will also help employers check whether disabled employees are happy with their current hours.
Mandatory workforce reporting puts the onus on disabled employees to disclose their disability to their employers.
“Reportable figures are not about how many disabled people there are in a workforce; they are about how many disabled people have chosen to tell their employer that they are disabled,” the BDF notes. “No employer should be pressurising disabled people to share this information at work if they do not want to.”
Asking employers to offer more flexible or part-time work arrangements, while also encouraging companies to narrow their disability pay gap, sends a mixed message.
According to the BDF, this must be resolved if employers are to offer more flexible work without fearing the potential impact on their pay gap.
Employers should identify any policies and practices that might create a poor workplace experience for those with disabilities.
Making adjustments and offering additional support can be more impactful than focusing in improving figures.
Companies should therefore record a qualitative assessment alongside any pay-gap figures, according to the BDF. Doing so will help employers explain the reasons behind any gaps and share best practices.

The UK government’s equality (race and disability) bill includes a new requirement for companies with 250 staff or more to report their ethnicity and disability pay gaps. While this proposal aims to highlight unfair pay discrepancies, such reporting can exacerbate some of the challenges disabled employees face, according to a new report from Business Disability Forum (BDF).
BDF surveyed 64 employers and 64 disabled employees for its report, Towards meaningful disability workforce and pay gap reporting – the challenges and unintended consequences. It claims pay-gap reporting that focuses solely on the numbers can "inadvertently incentivise” employers to make some opportunities in the workplace less inclusive.
The research found that businesses can sometimes decline reasonable adjustments for disabled employees – such as reduced hours or job-share arrangements – to avoid widening the company’s disability pay gap.