M-Legal has submitted its formal response to the UK Government’s consultation on extending mandatory pay gap reporting to cover ethnicity and disability. These proposals, part of the draft Equality (Race and Disability) Bill, offer a critical opportunity to improve workplace transparency, strengthen legal coherence, and address persistent structural inequalities across the UK economy.
What Is The Consultation About?
Since 2017, large employers have been required to report annually on gender pay gaps. The Government is now considering whether similar obligations should apply to ethnicity and disability. The consultation covers how data should be collected, reported, and acted upon, and explores whether public bodies should have additional duties to monitor recruitment, retention and progression.
This marks a key moment in the evolving discussion around fairness at work—and the role of law and data in realising it.
Why M-Legal Is Responding
M-Legal funds support and strategic litigation for individuals and communities facing structural discrimination, particularly where race, religion, and class intersect. We have a long-standing interest in the way UK legal frameworks fall short in protecting racialised and religious minorities, especially those whose experiences of discrimination are rendered invisible by outdated or fragmented definitions of race.
We view pay gap reporting as more than a technical requirement. It is a tool that, if designed well, can help challenge deep-rooted patterns of exclusion in recruitment, progression, and reward—particularly for those at the sharpest end of institutional bias.
Our Key Recommendations To Government
While we welcomed the overall direction of the proposals, our submission called for the Government to go further in ensuring that the new framework is legally coherent, inclusive, and enforceable. Our main recommendations included:
Beyond Compliance: A Call For Structural Fairness
Our response draws on leading legal and policy thinking to argue that pay gap transparency alone is not enough. What is needed is a joined-up equalities framework that recognises how disadvantage is produced through the intersection of race, religion, and socio-economic position -and that gives employers the tools and obligations to meaningfully respond.
As an organisation committed to justice and structural equity, M-Legal views this consultation as a key opportunity to lay the foundations for a more coherent, inclusive and impactful equalities regime.
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