# Pay gap reporting and action plans: UK benchmark 2026

> In 2026, 77.5% of UK organisations ran gender pay gap analysis at least annually (n = 267), and 4.6% did so for ethnicity (n = 261).

Source: https://lumihr.co.uk/research/pay-gap-reporting-2026
Author: David Whitfield (https://lumihr.co.uk/about/david-whitfield)
Answers: What percentage of UK employers conduct gender pay gap analysis?
Data: lumi reward benchmark · national · collection window 2026 H1
Review by: when the next collection window closes

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*lumi research · Collection window 2026 H1 · By David Whitfield*

**In the lumi reward benchmark, 77.5% of UK organisations conduct gender pay gap analysis at least annually (n = 267, 2026 H1), while on ethnicity 4.6% run the analysis at least annually and 24.1% run it partially (n = 261).**

> **Key findings**
> - 77.5% of organisations conduct gender pay gap analysis at least annually (n = 267). This is the common answer; "No" is rare, at 16.9%.
> - For annual ethnicity pay gap analysis, 4.6% answer "Yes" and 24.1% "Partially" (n = 261). "No" is the common answer, at 71.3%.
> - For disability pay gap analysis, 7.3% answer "Yes" and 17.2% "Partially", while 75.6% answer "No" (n = 262).
> - On readiness for ethnicity and disability pay gap reporting, 41.9% have not started and 6.6% are reporting-ready (n = 229, "Not applicable" excluded).
> - 73.7% do not publish an equality action plan (n = 266). 24.8% publish one that covers gender, and 17.7% one that covers menopause.
> - 82.6% have not started preparing to name providers of outsourced workers in their gender pay gap report (n = 230, "Not applicable" excluded).
> - 45.7% review incentive outcomes by protected characteristic (n = 267). 12.2% monitor promotion rates by protected characteristics routinely (n = 254).

## About the data

This paper reports how UK employers answered lumi's questions on pay gap reporting and equality action plans. The lumi reward benchmark covers 269 UK organisations across 14 sectors and five size bands. Data was collected in the 2026 H1 collection window. Each figure gives its base (n): the number of organisations that answered that question. Percentages are rounded to one decimal place, so a distribution can add up to 100.1%. Figures here are national. Sector and size comparisons are available to lumi members. See [how lumi works](/methodology) for the method.

## The legal context

Gender pay gap reporting is required of employers with 250 or more employees. This is a long-standing duty.

Gender equality and menopause action plans were introduced on a voluntary basis on 6 April 2026. They are due to become mandatory in 2027, with the timing to be confirmed.

Two questions in this paper are quoted as organisations saw them, including the way each question describes the measure it asks about: ethnicity and disability pay gap reporting, and naming providers of outsourced workers in gender pay gap reports. This paper makes no statement on the status or timing of either.

## How many UK employers conduct gender pay gap analysis?

The first question asks about analysis, not publication: *Does your organisation conduct gender pay gap analysis at least annually?* (n = 267).

"Yes" is the common answer, at 77.5% (207 organisations). "No" is rare, at 16.9% (45). "In development" is also rare, at 5.6% (15). Taken together, 22.5% do not have an annual analysis in place (16.9% + 5.6%).

The statutory duty is a reporting duty for employers with 250 or more employees. An annual analysis can serve that duty, but it can also feed pay review and bonus calibration. The data does not record its purpose. An organisation without it gives up a regular view of how pay decisions fall by gender, and avoids the cost of assembling the data and explaining what it finds.

A second question covers gender pay gap reports and outsourced workers, in the question's own words: *Are you prepared to name providers of outsourced workers in your gender pay gap report (ERA requirement, commencement date TBC)?* (n = 230). Organisations that answered "Not applicable" (36) are excluded from this base.

"Not started" is the common answer, at 82.6% (190 organisations). "Reviewing supplier data" is rare, at 10.0% (23). "Prepared" is rare, at 7.4% (17). In total, 17.4% have begun or completed their preparation (10.0% + 7.4%).

This question sits between reward and procurement. Preparation depends on supplier records: who the providers are and which workers they supply. That data may sit outside the reward team. The data does not show whether organisations that have not started are waiting for a commencement date or have not reviewed the question.

## Do UK employers analyse ethnicity and disability pay gaps?

Three questions ask about pay analysis on characteristics other than gender.

The first is *Does your organisation run ethnicity pay gap analyses at least annually?* (n = 261). "No" is the common answer, at 71.3% (186 organisations). "Partially" is an alternative, at 24.1% (63). "Yes" is rare, at 4.6% (12). In total, 28.7% answer "Yes" or "Partially" (4.6% + 24.1%).

The second is *Does your organisation run disability pay gap analyses (or pay equity analyses by disability status) at least annually?* (n = 262). "No" is the common answer, at 75.6% (198). "Partially" is rare, at 17.2% (45). "Yes" is rare, at 7.3% (19). In total, 24.5% answer "Yes" or "Partially" (7.3% + 17.2%).

"Partially" is an alternative for ethnicity analysis but rare for disability analysis. The questions do not define it. It could mean analysis of part of the workforce, of some pay elements, or on a cycle longer than a year.
Both kinds of analysis depend on employees sharing their ethnicity or disability status. Where few people share it, groups become small, gaps are harder to calculate reliably and individuals can become identifiable.

A related question asks about readiness for reporting: *How ready are you for ethnicity and disability pay gap reporting at 250+ employees, proposed under the Equality (Race and Disability) Bill?* (n = 229). Organisations that answered "Not applicable" (36) are excluded from this base.

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| Not started | 41.9% | 96 | common |
| Reviewing data readiness | 31.4% | 72 | alternative |
| Analysing gaps | 20.1% | 46 | alternative |
| Reporting-ready | 6.6% | 15 | rare |

The answers form a sequence of stages. 73.3% are at one of the two earlier stages (41.9% + 31.4%). 26.7% are at one of the two later stages, "Analysing gaps" or "Reporting-ready" (20.1% + 6.6%). "Reviewing data readiness" is an alternative in its own right. For these characteristics, the first task is often the data itself, before any gap can be measured.

The third question moves beyond protected characteristics: *Do you monitor pay outcomes by socio-economic background?* (n = 266). "No" is the common answer, at 77.1% (205 organisations). "Considering" is rare, at 14.3% (38). "Yes" is rare, at 8.6% (23). In total, 22.9% answer "Yes" or "Considering" (8.6% + 14.3%).

Socio-economic monitoring needs a definition before it needs a calculation. An organisation has to decide which measure of background to collect and ask employees to share it. That is a separate design choice from the pay analysis that follows.

## How many UK employers publish an equality action plan?

The next two questions are multi-select. Organisations could choose more than one answer, so the percentages cannot be added together.

The first is *Which pay gaps do you publish voluntarily, beyond statutory gender reporting?* (n = 265).

| Answer | % of base | Organisations |
|---|---|---|
| None | 65.7% | 174 |
| Ethnicity pay gap published | 18.1% | 48 |
| Disability pay gap published | 12.8% | 34 |
| CEO pay ratio (voluntary) | 7.5% | 20 |

65.7% answer "None": they publish no pay gap voluntarily beyond statutory gender reporting. 18.1% publish an ethnicity pay gap, 12.8% a disability pay gap and 7.5% a CEO pay ratio on a voluntary basis.

This question asks about voluntary publication and sets no frequency, so it is not directly comparable with the annual analysis questions above.

Publishing a gap is a different decision from calculating one. Publication invites questions about causes and planned action. It also sets a precedent: once a figure is published, not publishing it the following year is itself visible.

The second question is *Do you publish an equality action plan, and which areas does it cover?* (n = 266).

| Answer | % of base | Organisations |
|---|---|---|
| None | 73.7% | 196 |
| Gender | 24.8% | 66 |
| Menopause | 17.7% | 47 |
| Ethnicity | 8.3% | 22 |
| Disability | 6.8% | 18 |

73.7% answer "None": they do not publish an equality action plan. Among the areas, gender is the one most often covered, followed by menopause. These are the two areas named in the action plans introduced on a voluntary basis on 6 April 2026 and due to become mandatory in 2027.

An action plan is a public commitment to act and, by implication, to report on progress. A plan covering several areas can link pay, progression and health in one document. A plan covering one area is narrower and easier to deliver against.

## Do UK employers check incentives and promotions for pay equity?

The last two questions look at decisions that sit upstream of any pay gap figure: who receives incentive pay, and who is promoted.

The first is *Does your organisation review incentive outcomes by protected characteristic (where data is available and lawful)?* (n = 267). "Yes" is the common answer, at 45.7% (122 organisations). "Partially" is an alternative, at 30.7% (82). "No" is also an alternative, at 23.6% (63). In total, 76.4% review incentive outcomes fully or in part (45.7% + 30.7%).

Incentive outcomes are one place where pay gaps form. Awards often depend on ratings, discretion and eligibility rules, and each can produce different results for different groups. Reviewing outcomes at the point of award shows a pattern before it appears in a published figure. The question's wording notes the limits: data must be available and its use lawful.

The second is *Do you monitor promotion rates by protected characteristics to identify equity issues?* (n = 254).

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| Planned but not yet | 42.5% | 108 | common |
| Sometimes | 36.2% | 92 | alternative |
| Yes – routinely | 12.2% | 31 | rare |
| No | 9.1% | 23 | rare |

In total, 48.4% monitor promotion rates at least sometimes (12.2% + 36.2%). The common answer, "Planned but not yet", describes intent rather than practice.

Promotion decisions shape who reaches higher-paid roles. A gap in promotion rates can appear in pay figures later, even where pay for each role is set consistently. The difference between "Sometimes" and "Yes – routinely" is one of cadence: occasional checks give a snapshot, while routine monitoring gives a repeated measure.

## What the data means for reward decisions

The questions in this paper cover a chain of decisions: analysis, publication, commitment, and the pay and promotion decisions that produce the figures. Each step has its own trade-offs.

**Analysis or publication.** Analysis can stay internal and inform pay review without public commitment. Publication adds scrutiny and an expectation of explanation. 77.5% run annual gender analysis (n = 267). Voluntary publication of ethnicity (18.1%) and disability (12.8%) pay gaps comes from a separate question (n = 265).

**Breadth or depth.** "Partially" is an alternative for ethnicity analysis (24.1%) and for incentive reviews (30.7%). Partial analysis gives earlier sight at lower cost. It may miss groups, pay elements or periods where a gap sits.

**Data before analysis.** For ethnicity and disability reporting, 41.9% have not started and 31.4% are reviewing data readiness (n = 229). The quality of disclosure data sets what analysis is possible and how much weight its results can bear.

**Early or later commitment.** Action plans are voluntary and due to become mandatory in 2027. Publishing in the voluntary period tests an approach and signals intent. Waiting reduces the risk of committing to measures that later need to change.

A reward team working through these choices might ask:

- Which pay gaps do we analyse, how often, and who sees the results?
- Is our disclosure data good enough for ethnicity or disability analysis? How would we treat a gap based on small numbers?
- If we publish a gap voluntarily, what are we committing to explain the following year?
- Who holds the supplier data needed to name providers of outsourced workers: reward, procurement, or both?
- Do we look at incentive awards and promotion rates before they show up in reported pay figures?

## Frequently asked questions

**What percentage of UK employers conduct a gender pay gap analysis?**
In the lumi reward benchmark, 77.5% of UK organisations conduct gender pay gap analysis at least annually (n = 267, 2026 H1). 16.9% answer "No" and 5.6% have one in development, so 22.5% have no annual analysis in place (16.9% + 5.6%). Statutory gender pay gap reporting applies at 250 or more employees.

**Do UK employers run ethnicity and disability pay gap analysis?**
In the lumi reward benchmark, 4.6% of UK organisations run ethnicity pay gap analysis at least annually and 24.1% run it partially (n = 261, 2026 H1); for disability, 7.3% do so at least annually and 17.2% partially (n = 262). "No" is the common answer to both, at 71.3% and 75.6%. A separate question asks which pay gaps organisations publish voluntarily: 18.1% publish an ethnicity pay gap and 12.8% a disability pay gap (n = 265).

**Are UK employers ready for ethnicity and disability pay gap reporting?**
In the lumi reward benchmark, 6.6% of UK organisations are reporting-ready and 41.9% have not started (n = 229, "Not applicable" excluded, 2026 H1). In between, 31.4% are reviewing data readiness and 20.1% are analysing gaps.

**Do UK employers publish an equality action plan?**
In the lumi reward benchmark, 73.7% of UK organisations do not publish an equality action plan (n = 266, 2026 H1). Gender is the area most often covered, at 24.8%, followed by menopause at 17.7%, ethnicity at 8.3% and disability at 6.8%. The options are multi-select and can sum to more than 100%.

**Do UK employers check incentive awards and promotions for pay equity?**
In the lumi reward benchmark, 76.4% of UK organisations review incentive outcomes by protected characteristic fully or in part (45.7% + 30.7%, n = 267, 2026 H1). Promotion monitoring is less established: 48.4% monitor promotion rates at least sometimes (12.2% + 36.2%, n = 254), and the common answer is "Planned but not yet", at 42.5%.

**Are UK employers ready to name providers of outsourced workers in gender pay gap reports?**
In the lumi reward benchmark, 82.6% of UK organisations have not started preparing to name providers of outsourced workers in their gender pay gap report (n = 230, "Not applicable" excluded, 2026 H1). 10.0% are reviewing supplier data and 7.4% are prepared, so 17.4% have begun or completed preparation (10.0% + 7.4%).

## Related

- [How to prepare and publish your gender pay gap report](/guides/how-to-prepare-gender-pay-gap-report) — the steps from payroll snapshot to published figures.
- [How to calculate and report your ethnicity pay gap](/guides/how-to-calculate-ethnicity-pay-gap) — what to collect, how to handle small groups, what to publish.
- [Pay transparency and equal pay](/research/pay-transparency-equal-pay-2026) — benchmark findings on what UK employers disclose about pay.

## Notes

- Base, "Not applicable" handling and rounding are as described in "About the data".
- "Not applicable" answers are excluded from the base for two questions: *How ready are you for ethnicity and disability pay gap reporting at 250+ employees, proposed under the Equality (Race and Disability) Bill?* (36 answered "Not applicable"; n = 229) and *Are you prepared to name providers of outsourced workers in your gender pay gap report (ERA requirement, commencement date TBC)?* (36 answered "Not applicable"; n = 230). For all other questions, any "Not applicable" answers sit inside the base.
- The questions on voluntary pay gap publication and on equality action plans are multi-select. Each percentage is the share of the base choosing that option, and options can sum to more than 100%.
- Prevalence words (common, alternative, rare) are used for single-select questions only. Combined figures add listed percentages within one question, with the parts shown.

## Data appendix

All national figures used in this paper, as recorded in the lumi reward benchmark (collection window 2026 H1).

**Does your organisation conduct gender pay gap analysis at least annually?**  
Base: 267 organisations

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| Yes | 77.5% | 207 | common |
| No | 16.9% | 45 | rare |
| In development | 5.6% | 15 | rare |

**Does your organisation run ethnicity pay gap analyses at least annually?**  
Base: 261 organisations

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| No | 71.3% | 186 | common |
| Partially | 24.1% | 63 | alternative |
| Yes | 4.6% | 12 | rare |

**Does your organisation run disability pay gap analyses (or pay equity analyses by disability status) at least annually?**  
Base: 262 organisations

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| No | 75.6% | 198 | common |
| Partially | 17.2% | 45 | rare |
| Yes | 7.3% | 19 | rare |

**How ready are you for ethnicity and disability pay gap reporting at 250+ employees, proposed under the Equality (Race and Disability) Bill?**  
Base: 229 organisations · "Not applicable" excluded from base

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| Not started | 41.9% | 96 | common |
| Reviewing data readiness | 31.4% | 72 | alternative |
| Analysing gaps | 20.1% | 46 | alternative |
| Reporting-ready | 6.6% | 15 | rare |

**Which pay gaps do you publish voluntarily, beyond statutory gender reporting?**  
Base: 265 organisations · more than one answer allowed

| Answer | % of base | Organisations |
|---|---|---|
| None | 65.7% | 174 |
| Ethnicity pay gap published | 18.1% | 48 |
| Disability pay gap published | 12.8% | 34 |
| CEO pay ratio (voluntary) | 7.5% | 20 |

**Do you monitor pay outcomes by socio-economic background?**  
Base: 266 organisations

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| No | 77.1% | 205 | common |
| Considering | 14.3% | 38 | rare |
| Yes | 8.6% | 23 | rare |

**Do you publish an equality action plan, and which areas does it cover?**  
Base: 266 organisations · more than one answer allowed

| Answer | % of base | Organisations |
|---|---|---|
| None | 73.7% | 196 |
| Gender | 24.8% | 66 |
| Menopause | 17.7% | 47 |
| Ethnicity | 8.3% | 22 |
| Disability | 6.8% | 18 |

**Are you prepared to name providers of outsourced workers in your gender pay gap report (ERA requirement, commencement date TBC)?**  
Base: 230 organisations · "Not applicable" excluded from base

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| Not started | 82.6% | 190 | common |
| Reviewing supplier data | 10.0% | 23 | rare |
| Prepared | 7.4% | 17 | rare |

**Does your organisation review incentive outcomes by protected characteristic (where data is available and lawful)?**  
Base: 267 organisations

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| Yes | 45.7% | 122 | common |
| Partially | 30.7% | 82 | alternative |
| No | 23.6% | 63 | alternative |

**Do you monitor promotion rates by protected characteristics to identify equity issues?**  
Base: 254 organisations

| Answer | % of base | Organisations | Prevalence |
|---|---|---|---|
| Planned but not yet | 42.5% | 108 | common |
| Sometimes | 36.2% | 92 | alternative |
| Yes – routinely | 12.2% | 31 | rare |
| No | 9.1% | 23 | rare |

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