Ethnicity and disability pay gap reporting: where organisations stand
Key findings
- 35% of organisations have their ethnicity and disability pay gap data.
- 28% plan to communicate it externally, now or once they have the data.
- 35% will not do external comms, whether or not they have the data.
- 22% of marketing leads don't know whether the data exists or whether it will be communicated.
Why this matters now
The Government has confirmed that ethnicity and disability pay gap reporting will become mandatory for employers in Great Britain with 250 or more employees. Its consultation response, published on 25 March 2026, says the rules will follow the existing gender pay gap framework and will be brought in through the Equality (Race and Disability) Bill. No start date has been set.
Gender pay gap reporting showed what happens when numbers go public without a plan: the figure becomes the story. Marketing and comms teams are the ones who will be asked to explain it.
How many organisations have their pay gap data?
About a third. 35% of marketing leads say their organisation has the data: 17% have it and are planning a comms campaign around it, and 18% have it and won't do external comms.
A further 28% don't have the data yet. Of those, 11% say they will communicate once they do and 17% say they won't.
How many will communicate their pay gap figures?
Fewer than three in ten. Adding those who have the data and plan a campaign (17%) to those who will communicate once the data arrives (11%) gives 28%.
A larger group, 35%, has decided against external comms: 18% who have the data and 17% who don't yet.
How many don't know?
More than one in five. 12% of marketing leads don't know whether their organisation has the data, and 10% don't know whether it will communicate. Another 15% don't think the reporting would apply to them.
More organisations plan to stay quiet than to speak
Preparedness for ethnicity and disability pay gap reporting
View data
| Answer | % |
|---|---|
| Will communicate (28%): Have the data, planning a comms campaign around it | 17% |
| Will communicate (28%): Don’t have the data, will do comms once they do | 11% |
| Won’t communicate (35%): Have the data, won’t do external comms | 18% |
| Won’t communicate (35%): Don’t have the data, won’t do external comms | 17% |
| Don’t know (22%): Don’t know whether they have the data | 12% |
| Don’t know (22%): Don’t know whether they’ll do comms | 10% |
| Not applicable: Don’t think this would apply to them | 15% |
What this means
Staying quiet is a reasonable choice. It stops being one when the numbers are published anyway.
For comms and marketing leads, three steps are worth taking before the data lands.
- Find out whether the data exists. One in eight marketing leads don't know. That is the first conversation to have with HR.
- Decide the position before the figure. "We won't comment" is also a message. Choose it on purpose.
- Prepare the explanation, not the celebration. A pay gap figure needs context: what it measures, why it is what it is and what is being done.
The organisations that struggle will be those in the 22%, who learn their number at the same time as everyone else.
Frequently asked questions
Are UK employers ready for ethnicity and disability pay gap reporting?
35% of UK organisations have their ethnicity and disability pay gap data, according to a survey of 300 marketing leads by The Reality Department. 22% of marketing leads don't know where their organisation stands.
Will companies publish their ethnicity pay gap?
28% of organisations plan to communicate their ethnicity and disability pay gap data externally. 35% say they will not do external comms.
How many organisations think pay gap reporting doesn't apply to them?
15% of marketing leads don't think ethnicity and disability pay gap reporting would apply to their organisation.
Methodology
The Reality Department, in partnership with VCCP, surveyed 300 UK marketing leads at organisations with 50 or more employees. Fieldwork: September 2026. Figures reflect what marketing leads report about their own organisation.
Related: Why do brands run ED&I campaigns, and what stops them?
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