Following the introduction of gender pay gap reporting, the UK government has now announced plans to introduce mandatory disability pay gap reporting.

At first glance, this may feel like a logical next step. Another dataset. Another report. Another compliance requirement.

But in reality, this is a more complex and nuanced shift.

Disability is not always visible, consistently defined or widely disclosed. And when you bring neurodiversity into the conversation, this complexity increases even further.

This isn’t just about measuring pay differences. It raises deeper questions about how organisations understand disability, how safe employees feel disclosing it, and how workplace structures influence progression, performance and pay over time.

What Is Disability Pay Gap Reporting?

Disability pay gap reporting will require organisations to measure and publish the difference in average pay between disabled and non-disabled employees.

It is expected to follow a similar structure to gender pay gap reporting, including:

• Mean and median pay differences
• Bonus gaps
• Pay quartile distribution
• Representation data

The aim is to increase transparency and highlight inequalities that may otherwise go unnoticed.

However, the effectiveness of this reporting will depend heavily on one factor: the quality of the data organisations are able to collect.

What Has the Government Announced So Far?

While full details are still being developed, the government has confirmed its intention to move forward with disability pay gap reporting as part of a broader focus on workplace equality.

What we know so far suggests:

• Reporting will likely apply to larger employers (250+ employees)
• There will be an emphasis on data transparency and accountability
• Employers will be encouraged to improve disclosure rates
• Further guidance is expected on definitions of disability and data collection approaches

This signals a shift beyond awareness. Organisations will be expected not only to report on inequality, but to demonstrate that they understand it and are taking steps to address it.

The Disclosure Challenge: Why the Data May Not Reflect Reality

One of the biggest challenges with disability pay gap reporting is disclosure.

Unlike gender, disability is not always visible, and many employees choose not to disclose a disability at work.

There are a number of reasons for this:

• Employees may not have a formal diagnosis
• They may not identify with the term “disabled”
• There may be concerns about stigma or career impact
• Past experiences may have reduced trust in how disclosures are handled

This is particularly important when considering neurodiversity.

Many neurodivergent employees, including those with ADHD, autism or dyslexia, do not necessarily associate themselves with having a disability. Some may view their differences as strengths, while others may not feel that their experience fits within traditional definitions of disability.

As a result, they may not disclose at all, meaning they are not captured in disability data.

This creates a significant risk for employers.

If a large proportion of neurodivergent employees are not included in reporting, the data may underestimate both the size of the population and the extent of any pay gap.

Why Neurodiversity Needs to Be Part of the Conversation

This is where organisations need to think more carefully about how they approach data collection.

At least 1 in 5 people are neurodivergent, yet this is rarely reflected in workforce data. If disability pay gap reporting is based solely on traditional definitions of disability, it is likely to miss a substantial proportion of employees.

One practical step is to ensure that neurodiversity is included as a distinct category within equal opportunities monitoring forms, rather than relying solely on a single disability question.

This gives employees more options in how they identify and can increase engagement with data collection processes.

It also provides organisations with a more accurate picture of their workforce, allowing them to:

• Identify patterns in progression and pay
• Understand where barriers may exist
• Design more targeted and effective interventions

Without this level of insight, organisations risk making decisions based on incomplete data.

The Structural Drivers Behind the Pay Gap

It is also important to recognise that pay gaps do not typically arise from direct pay discrimination.

Instead, they develop over time through structural factors such as:

• Access to opportunities
• Progression pathways
• Performance management processes
• Workplace design and expectations

For example, if success within an organisation is tied to behaviours such as quick verbal communication, constant responsiveness or navigating informal networks, this may disadvantage some neurodivergent employees.

Over time, this can impact promotion, salary progression and overall career trajectory.

Disability pay gap reporting may highlight these outcomes, but it will not explain them on its own.

Employers will need to look more deeply at how their organisation operates in practice.

What Employers Should Be Doing Now

Although full requirements are still emerging, there are clear steps employers can take to prepare.

1. Improve How You Capture Both Disability and Neurodiversity Data

Rather than relying on a single question, consider how you create multiple, ongoing opportunities for employees to share information about disability and neurodiversity.

This might include:

• Updating equal opportunities forms
• Providing clear definitions and examples
• Offering reassurance around how data will be used

The aim is to create a process that feels accessible, inclusive and safe.

2. Build Trust Around Disclosure

Data collection will only be effective if employees feel confident disclosing.

This means demonstrating, in practice, that disclosure leads to positive outcomes.

For example:

• Reasonable adjustments are implemented effectively
• Managers respond to disclosure with understanding and confidence
• Employees continue to progress and develop

Without this, requests for disclosure are unlikely to result in meaningful engagement.

Learn more about our manager training on supporting neurodivergent employees.

3. Look Beyond the Numbers

Pay gap reporting is a starting point, not a solution.

Employers should use this data to ask deeper questions about their organisation, including:

• Who is progressing and who is not?
• Where are barriers emerging?
• How are performance and potential being assessed?

This is where the real opportunity for change sits.

4. Equip Managers to Handle Complexity

Managers will play a critical role in how this is experienced day to day.

They need to feel confident:

• Responding to disclosures
• Implementing reasonable adjustments
• Managing performance fairly and consistently

Without this capability, even well-designed policies may not translate into practice.

5. Review How Work Is Designed

Finally, organisations should reflect on how work is structured. This includes how tasks are communicated, how priorities are set and how success is defined.

Often, small adjustments in these areas can have a significant impact on both performance and inclusion.