The Government guidance on ethnicity pay reporting is complex. Reporting is voluntary but many employers are already collating the relevant data. They should allow plenty of time to gather and verify their data; make the calculations; analyse and understand the reasons behind any patterns identified and prepare their written analysis and action plan.
Where the data shows significant pay differentials between particular ethnicities, what can be done to close the gap?
Blake Morgan Senior Associate Madeleine Mould considers the factors employers should take into account when developing an action plan while ensuring that their well-meant strategies remain within the law, in an article first published in Reward Strategy digital magazine issue 244.
Developing an action plan
Employers may feel slightly helpless to tackle ethnicity pay gaps in their organisation – with so many factors at play, where do you begin, and how do you ensure that your well-meant strategies for improving diversity remain within the law?
The first step will be to consider the likely reasons behind any patterns. That should allow the employer to develop strategies that are specific to their organisation, sector and geography, increasing their likely effectiveness.
Positive action v positive discrimination
When considering strategies to tackle ethnicity pay gaps, employers must be careful not to stray into positive discrimination. Serious commitments are needed to tackle diversity gaps and it is important that employers are not so paralysed by fear that they do nothing. However, employers must not discriminate against those from better paid ethnicities in an effort to improve their statistics.
Read the article in full here.
Explore more insights
Articles 02 October
Employment Rights Act 2025: Right to trade union statement delayed to January 2027
What do employers need to provider workers with concerning their rights to join trade unions? We look at…
Articles 25 September
Right to Work reforms from 1 October 2026: what employers should know
Employers that engage labour through agencies, contractors or other flexible workforce arrangements face additional Right to Work obligations…
Articles 24 September
Thank you, Next! Equal pay ruling overturned in favour of Next
Next has been successful in appealing the equal pay litigation ruling made in 2024 by the Employment Tribunal.

