U.K. proposed pay gap reporting

Employer Action Code: Monitor

There has been recent legislative activity on proposed employer mandates related to gender pay gap reporting, ethnicity and disability pay gap reporting as well as pay transparency across the U.K. This includes separate specific initiatives for Northern Ireland (NI) where employment law is devolved (meaning, for example, that the existing U.K. gender pay gap reporting mandate for companies with 250 or more employees does not apply to NI because separate NI legislation has not yet been implemented).

Key details

Northern Ireland

The NI Department for Communities has ended public consultations on proposed gender pay gap reporting regulations. The proposals would require companies with 250 or more employees in NI to disclose information regarding gender-based compensation gaps (the difference between average earnings of men and women, relative to men's earnings) within their workforce annually by April 4. The regulations, once finalized and approved, are expected to take effect in 2027. The 2016 Employment Act (Northern Ireland) mandates — in general terms — pay gap reporting based on gender, ethnicity and disability, but to date the act has not been brought into force
Note: In their response to the consultation, NI’s Equality Commission and Human Rights Commission raised concerns that the proposals do not address the EU Pay Transparency Directive (see January 2023 Global News Brief, European Union: Agreement on Pay Transparency Directive). Both commissions hold the view that NI should transpose the directive into law by June 2026, with required gender pay gap reporting annually for companies with 150 or more employees (starting from 2027) and once every three years for companies with 100 to 149 employees (starting from 2031), in line with the EU directive. As the U.K. is no longer in the EU, such directives do not apply to it.
Separately, the NI government is considering pay gap reporting based on ethnicity and disability, but details are yet to be released

England, Scotland and Wales

A U.K. government consultation on proposed mandatory ethnicity and disability pay gap reporting for employers with 250 or more employees, as set out in the employment Equality (Race and Disability) Bill, closed on June 10, 2025. It’s unlikely that the bill, if approved, would take effect before late 2026, given that U.K. employers have the immediate challenge of complying with various measures proposed under the pending Employment Rights Bill (see October 2024 Global News Brief, Proposed stronger employment rights for employees). Also, as part of shaping the bill’s overall provisions on equal pay, discrimination and workplace conduct, the government issued a call for evidence on greater pay transparency asking for initial insights on the merits of requiring greater transparency to support delivery of equal pay (similar to the EU Pay Transparency Directive). The call for evidence closed on June 30, 2025

Employer implications

Employers should monitor the separate proposals and prepare for their likely implementation. According to the NI Statistics and Research Agency, women's hourly earnings were 7.3% below those of men (compared with an EU average gap of 13%). Employers with operations in NI may wish to begin preparing for the gender pay gap reporting mandate by conducting pay gap analyses similar to those currently required elsewhere in the U.K., in order to identify any areas needing further attention.

Contacts

Tamsin Sridhara

Global Pay Equity Lead

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Tabi Moloi

Analyst, Rewards

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Eva Jesmiatka

Europe Pay Equity Lead, WTW

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