For large employers in the UK, disability pay gap reporting recently became a reality. Earlier this year, it was announced that both ethnicity and disability pay gap reporting will become mandatory for employers of over 250 staff, who will be expected to publish data on gender and disability salary disparities.
This is certainly a positive step for disability inclusion and equality in general. However, while the legislation aims to improve transparency and promote workplace equality, there is a worry that organisations might be attempting to measure an issue they do not fully understand.
The fact is, most disabilities cannot be seen, and therefore, disability pay gap reporting will rely heavily on whether or not staff choose to disclose their disability in the workplace.
Whilst this may sound like it will impact just a select few people, consider the following. According to research from Bupa, 43% of employees with hidden disabilities have chosen not to disclose their disability at work. Now, considering that around 80% of all disabilities are hidden, and that 16.8 million people in the UK have one, that equates to a huge number of employees who are currently keeping their disabilities under wraps.
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Why hide?
There are many reasons why staff choose to keep their disability a secret. Some people are private and wish to keep that information to themselves, but most reasons stem from fear of colleagues’ perceptions, stigma, and general worries about career development. These issues are almost always connected to cultural factors that exist in the workplace.
The consequences of this are, of course, that if an employee feels uncomfortable disclosing their disability and it remains unknown, an organisation will inevitably report inaccurate data, which can lead to flawed conclusions and ineffective actions based on false information.
The risks associated with inaccurate data
Aside from providing the Government with false information (which can lead to a misinformed national perception of disability equality), one of the biggest dangers is companies creating a distorted picture of workplace disability and then acting on it.
Consider, for example, a company that appears to have a minimal disability pay gap. After collecting the data, the senior staff and the HR department consider the findings a sign of the company’s equality and celebrate internally, seeing themselves as a disability-inclusive organisation.
However, if you were to look at things under a microscope, you may find that only a small portion of people with a disability actually disclosed it in the report, and those who did disclose were mainly people with visible disabilities (meaning even if they wanted to hide them, they wouldn’t have been able to).
In reality, the organisation may employ a much higher number of people with hidden disabilities, many of whom feel uncomfortable revealing them. The result is that the company remains unaware of underrepresentation and low disclosure, fails to understand the true pay gap issue, yet sees this as an inclusion milestone and therefore relaxes its efforts.
Another example could be a company realising that only 4% of its workforce has disclosed a disability. In response, they decide to hire more individuals with disabilities and run inclusive recruitment campaigns to boost application numbers. However, unbeknownst to the company, many existing employees with disabilities choose not to disclose because they fear negative reactions from colleagues, feel unsupported, and face untrained managers and a complicated process for requesting reasonable adjustments.
As a result, while the company may increase its hiring of employees with disabilities in order to improve these percentages, these staff members leave quickly due to a toxic workplace culture that senior management remains unaware of.
So how do we avoid such a scenario and encourage people to openly disclose their disabilities?
Culture before compliance
One of the biggest misconceptions about disability reporting is the assumption that employees will naturally disclose simply because their employer has asked them to. When asked, an employee will consider the potential outcomes, risks, benefits and pitfalls of sharing this information.
If they suspect or feel that their company will be unsupportive, that it will cause difficulties, or that revealing it could hamper their chances of development, they will choose not to disclose. For a recent example, consider the case of F vs J (2025) in which a university lecturer with autism demanded anonymity at his employment tribunal because he felt (and showed evidence to back it up) that his diagnosis being made public would harm his future career prospects.
If we want disability pay gap reporting to be of value, we first need to address how well an organisation attracts, recruits, and retains staff with disabilities. Most importantly, an inclusive culture must be developed.
Ideally, before an organisation attempts to gather this information, it should consider how staff feel about the company culture and its current approach to inclusivity. It should gain a good understanding through surveys and actively engage in conversations with staff members with disabilities. It should also consider the findings and assess whether indicators such as the number of staff who anonymously select “prefer not to say” when asked about disability is high. Whilst this information may not be a direct reflection, it may give some indication of how disability is culturally perceived.
Building trust through positive change
It is incredibly important that employees feel confident that revealing their disability will lead to improved working conditions for them, not judgment or further workplace complications. This is best achieved when disability inclusion is visible in practice and evident in everyday working life.
For example, if employees notice that all staff are undergoing disability awareness training, that the company is aiming to become a Disability Confident leader, that recruitment drives are accessible, and that reasonable adjustments are successful and easily accessible, these meaningful actions will gradually build trust, and disclosure rates will naturally rise.
Businesses also need to welcome disclosures, not as logistical headaches but as opportunities to get staff working more effectively, bringing their best selves to work.
After this, it should be considered whether performance management processes and workplace support are implemented correctly and efficiently, and whether managers are knowledgeable and well-versed in working with staff with disabilities. It should also be assessed which departments employ the most people with disabilities and whether they are represented across all areas of the business.
A critical moment for employers
Essentially, pay gap reporting for larger companies marks a positive milestone for disability equality and has the potential to drive workplace development. It can improve accountability and transparency and push organisations to create more inclusive and equal environments.
However, reporting alone will not solve any underlying issues. Before a company gathers this data, it should address any cultural problems and take stock of how it currently supports staff with disabilities.
If we want reliable data, the first step for any company is to create a workplace that encourages openness. To do this, employees making a first-time disclosure must feel confident that they will be supported and that their honesty will benefit them. To gain this trust, we must first show staff that their workplace has a culture that embraces, understands and meaningfully supports disability.
Chris Jay is an accomplished training facilitator, public speaker, commentator and writer on the topic of disability awareness. Chris provides training for a variety of businesses and organisations in the education sector including schools and universities, training people to be understanding and aware of disability and the needs, challenges and unique life experiences of people with disabilities.
Prior to launching his training company, Bascule Disability Training, Chris worked as a Training Facilitator and Project Manager for the disability awareness charity- Enable Me, where he developed and delivered training programmes for businesses, universities and schools. He was later appointed as the Executive Chairman of the charity.
- Chris Jay
- Chris Jay
- Chris Jay
