The purpose of EPG Reporting is to advance fairness and to ask companies to build evidence and show where and why racial disparity exists, underpinned with data. It’s vital for stakeholders like you to respond to the government consultation before the 10 June 2025 deadline. 

This addresses whether employers should report the same six measures as Gender Pay Gap reporting.

The ethnicity pay gap reporting is inherently more complex. The gender pay gap only compares two categories – male and female genders – however, there are far more categories for ethnicity to take into account.

We recommend collating and adding two additional statistics before applying the standard six measures from the Gender Pay Gap reporting framework: 

1. The proportion of an employer’s total UK workforce from a non-white ethnic background.
2. The proportion of employees who have disclosed their ethnicity. 

We recommend that narratives and action plans become a mandatory requirement from the outset.

Narratives explain findings by outlining the nature and causation of pay gaps.
Action plans outline what companies are doing to fix pay gaps.

How EPG reporting is undertaken is crucial; without mandatory narratives and action plans, companies will not be compelled to tackle the ethnicity pay gap, despite reporting evidence of its existence. 

This question covers enforcement.

Lessons from the gender pay gap shows that without mandatory action plans and enforcement, transparency alone doesn’t lead to change. Enforcement must be part of the solution from day one.
We recommend the government adopt a policy of naming the companies that fail to submit their ethnicity pay gap reports.

This will help raise standards, build trust, and ensure reporting leads to real progress — not just a box ticking exercise. 

Question 26 and 27 asks about reporting ethnicity pay gap data.
Disaggregating the data — breaking it down by ethnic group — helps employers spot where gaps exist between different ethnic groups, and where they need to focus efforts to attract, retain or support specific groups.

However, splitting the ‘White’ category too early (e.g. into ‘White British’ and ‘White Other’) can overstate the proportion of ethnic minority staff, which risks distorting the picture.

We recommend: 

1. Using White British as the baseline for comparisons 

2. Being consistent and transparent in how all groups are defined and reported
   

The ONS lists 18 ethnicity categories. We suggest a phased approach starting with the five broad ONS categories and binary reporting in the early phase, then expanding to the full 18 over time as data quality improves.