Will the Act address gender, ethnicity, or disability pay gaps?

Yes. The Act strengthens measures to improve pay transparency and help employers take action to reduce workplace inequalities.

For gender pay gaps, employers with 250 or more employees can currently publish a voluntary Equality Action Plan alongside their gender pay gap report. Subject to secondary legislation, this is expected to become mandatory from spring 2027. The plan will set out steps to address the gender pay gap and support employees experiencing menopause.

The Employment Rights Act 2025 does not introduce ethnicity or disability pay-gap reporting. The Government has committed to introducing mandatory reporting for employers with 250 or more employees through separate legislation. The detailed requirements have not yet been enacted.

It is important to remember that a pay gap is different from equal pay. Equal pay law requires men and women to receive equal pay for equal work. A pay gap measures the difference in average earnings between different groups across an organisation and can reflect issues such as occupational segregation, progression opportunities and representation at senior levels.

What this means for union reps

• Pay gap reporting can provide valuable evidence to support collective bargaining on pay, recruitment, promotion, training and career progression.
• Reps should encourage employers to involve unions in developing and reviewing Equality Action Plans and any actions to address ethnicity or disability pay gaps.
• Published pay gap data can help identify patterns of inequality and inform negotiations on workplace policies and practices.
• Reps should remember that reducing pay gaps requires more than equal pay compliance — it often involves tackling wider barriers to equality, inclusion and progression at work.