The government consultation on disability workforce reporting for large employers closed on 8 April 2022, with a response due to be published by 17 June 2022. This is a complex issue, and there is much debate surrounding the utility of mandatory disability reporting. This blog will explore the Business Disability Forum’s (BDF) recent response to the consultation, in which it outlined why increasing voluntary reporting is a more desirable alternative to a mandatory approach.

The Office of National Statistics disability pay gap statistics

On 25 April 2022, the Office of National Statistics published new data around the disability pay gap (DPG). If you missed this, see our blog last week where we explored the key points – the headline takeaway is that the DPG has increased by 2.1% since 2014.

What was the Business Disability Forum’s consultation response?

The BDF published its response to the government’s consultation on mandatory disability reporting in April 2022. In formulating its response, the BDF formed a working group of 64 employers and considered mandatory reporting against the following questions:

  • How far mandatory disability reporting would contribute to reducing the disability employment gap?
  • How far mandatory disability reporting would increase transparency from employers?
  • Would a mandatory reporting requirement from employers improve inclusive experiences of work?

BDF’s research found that a mandatory approach to reporting would not directly impact any of the issues that the government consultation sought to address. It therefore disagreed with a mandatory approach to disability reporting for the following five key reasons:

  • Mandatory disability workforce reporting would only apply to large employers. However, most UK employers are small and medium-sized employers. The mandatory reporting proposals also fail to capture disabled people looking for work or out of work.
  • A common argument for introducing mandatory disability reporting is that gender pay gap reporting is mandatory. Despite this, a high number of employers do not report on their gender pay gap. Additionally, evidence shows increasing gender inequality in the workplace despite mandatory reporting.
  • Disabled employees were actually not fond of a mandatory approach.
  • The number of disabled people employed in an organisation does not reveal the experience disabled employees have in that organisation.
  • Employees emphasised the difference between identifying as being “disabled” and telling their employer they have a disability.

What are the Business Disability Forum’s recommendations?

In their response to the consultation, the BDF outlines three key recommendations. These are:

  • Supporting the increased uptake of voluntary reporting (one option is via a reviewed and updated Voluntary Reporting Framework which is currently little known about by employers).
  • An approach which focuses on the experience disabled people have at work, rather than the number of disabled people in an organisation.
  • An approach which allows employers to use their own “brand” vocabulary and narrative about disability in the workplace which is co-produced with disabled employees in their organisation.


The government’s response is due to be published by 17 June 2022. Whether it intends to introduce mandatory reporting remains to be seen. What is clear is that employers are taking a variety of approaches to disability reporting, with many waiting to see the outcome of the government’s consultation. Others believe that by taking steps now to support disabled employees, including monitoring and reducing the disability pay gap, they will reap benefits such as creating a more inclusive culture and gaining access to a wider talent pool. These employers may also end up better placed to comply with any new reporting requirements the government may make.