Mandatory Disability Reporting For Large Employers Is Introduced

Written by Astriid Volunteer Sabeeha Kassam

The government’s National Disability Strategy has been collated from feedback from disabled people and offers over 100 opportunities and actions to improve the issues that most affect them in their day-to-day lives. The strategy lays out ways that transport can be more accessible, how opportunities for education can be extended, and how to target unhelpful perceptions of disabled people across society.

Another new step supports mandatory disability reporting for large employers with over 250 employees. Here’s what you need to know:


The disability employment gap is currently at 28.4%. There has been some progress towards reducing the gap: the Equality Act 2010 stipulates employers must make reasonable adjustments, and the Disability Confident Scheme covers 11 million paid employees. However, there is work to be done. Everyone, who can and wants to, deserves the opportunity to find meaningful work and to progress in their careers.

The current disability reporting framework is voluntary, but a mandatory requirement for any Disability confident Level 3 employer. Evidence around the use of this framework is currently limited. The Chartered Insititute of Personal Development (CIPD) noted in April 2021 that…

  • Only 21% of respondents were aware of the framework. This reflects limited awareness across sectors in small, medium or larger businesses.
  • Of that, 37% adopted part of the framework.
  • Over a quarter of respondents (28%) reported they had no plans to adopt the framework.
  • 54% of small and medium enterprises who were aware of the framework had no plans to incorporate it.

And on reporting and guidance:

  • 3/5 of respondents reported their organisation had a supportive framework to attract, recruit and retain talent with a disability or long term-health condition.
  • Developing line manager confidence is essential in the ability to attract, recruit and retain this talent, but less than a 1/3 of organisations provide managers with that training and guidance.
  • Forty percent of respondents reported that their organisation collects some workplace disability data, but this data is rarely published externally. Public sectors are twice as likely (69%) than private (29%) or non-profit sectors (34%) to report their fundings.

The report also identified that according to 2/3rds of respondents, the main barrier to reporting was, a lack of disability disclosure from talent. Some smaller organisations reported being they felt no need to collect the data, as they had no disabled people on their team.

Potential benefits of disability reporting

Historically, disability has been seen as a protected characteristic that rarely centres in the conversation about diversity. In the UK there are at least 14 million disabled people, and only 4.4 million in work. However, the real number could be higher due to a fear of disclosure or a lack of understanding as to who can identify as disabled. If talent however do disclose, organisations are better able to remove barriers in the workplace, such as inaccessible physical features, inadequate technology, or a lack of support or understanding regarding their condition.

The voluntary framework has a different definition of disability from the legal definition within the Equality Act. Talent may consider themself different, or without a diagnosis, or feel the impact on their day-to-day life is not significant enough. It is thought that if the framework asked about long-term conditions or disabilities that require changes to their job or the way it is done, this would help organisations know how to improve inclusivity.

Challenges in disability reporting for individuals include a fear of stigma, hindering their ability to progress, or how team members will perceive them. Reporting this data can also trigger legal liability for certain disability discrimination claims, such as a failure to make reasonable adjustments. Data could be collected anonymously, but this statistic only goes so far in addressing inclusivity if an organisation cannot identify the needs of an employee.

There can be much done to address these challenges, to foster an environment of trust. Managers could share their own experiences with long term health conditions, organisations can think about how they address the topic on their websites, training sessions on disability awareness could be provided, and health and well-being could become a higher priority on the agenda. This will make employees feel less alone and more empowered.

The Business Disability Forum (BDF) have stated the case against mandatory reporting, noting that there is a huge difference between hiring disabled talent and inclusivity:

  • It only applies to large employers and only captures data of talent for those in work. Most employers in the UK are small and medium size businesses, and data on job searching and falling out of employment needs to be accessible for them too.
  • We hear that gender pay gap reporting is mandatory, but in practice it is not routinely carried out. There are also insufficient resources to ensure this legally.
  •  Disabled have reported they feel it would leave them perceived as ‘‘hard work’’ by government and in the workplace. With changes to Access To Work Grants and benefit payments, the background of COVID-19, changes to shielding and mandatory mask wearing, and the extra costs of disability, many are concerned about the backdrop around which this discussion is taking place.
  • Employers and employees being unfamiliar with the term disability.

In conclusion, many have commented about the gender pay gap calculation being too crude to be an effective calculation, but without there being debate on the topic itself, how do we create effective change?

Without mandatory transparency, employers won’t feel publicly accountable, or have to explain why that gap still exists and what their company is doing to bring about real change. With the cost-of-living crisis, COVID-19, UK skills crisis and an aging workforce, there has never been a greater need for a transparency policy with a good evidence base, designed to ensure a fair and equitable society.

Written by Astriid volunteer Sabeeha Kassam


Here at Astriid, we match talented people with long-term conditions with meaningful work. We also help employers to diversify their workforce and harness the skills of our Invisible Talent Pool. To find out more and sign up as a candidate or employer, visit our website!