Pay transparency revolution: the view from the UK

As part of our series on the pay transparency revolution, this blog post focuses on the landscape in the UK. The UK has a well-developed framework of protection for equal pay rights as well as a system of reporting which requires employers to report on differences in pay between groups with protected characteristics and encourages them to close any pay gaps. This area continues to develop in the UK, including through recent government proposals. This blog post sets out the key takeaways.

The current framework

The current equal pay framework in the UK is the Equality Act 2010, which enshrines the right to equal pay between men and women for equal work. To claim equal pay, a claimant employee must demonstrate they are doing 'equal work' to a comparator of the opposite sex and that the comparator receives higher pay. If the claimant can do this, they will be automatically entitled to the comparator’s higher pay unless the difference in pay can be explained by the employer and the reason given is not discriminatory. 

The legislation provides protection for three types of ‘equal work’: 'like work' (applicable where the work undertaken by the claimant and comparator is similar), 'work rated as equivalent' (applicable where there has already been a relevant job evaluation), and 'work of equal value' (where the claimant and comparator have different jobs but the claimant says that the value of that work is the same, in which case the tribunal usually appoints experts to conduct a detailed evaluation of the work to assist the tribunal in determining whether the work is ‘work of equal value’). Although the EU Pay Transparency Directive (PTD) does not apply in the UK, there has been interest in how the UK has historically tested ‘work of equal value’ as the PTD will require employers to look at the value of entirely different roles within their organisation. 

Historically, group equal pay claims were only seen in the public sector. However, over the past decade, we have seen them move into the private sector as well. This expansion into the private sector is largely because of the rise of ‘no win, no fee’ law firms whose business models depend on widescale claimant recruitment. We expect to see a further increase in group equal pay claims from 2026 onwards, particularly in light of incoming legislation which will increase the scope of equal pay protection to other groups.

What’s to come?

On the gender pay gap:

In the Employment Rights Act 2025, employers will be required to develop and publish ‘Equality Action Plans’ setting out how they intend to tackle their gender pay gap and support employees around the menopause. Almost nine years after gender pay gap reporting was introduced in the UK, these measures represent a shift from simply requiring employers to report information to requiring employers to take action with the aim of remedying any pay gaps. 

The requirement for employers to implement these action plans will be mandatory from around Spring 2027, following their introduction on a voluntary basis from 6 April 2026. The plans will need to detail effective actions (backed up by evidence) that the employer intends to take to improve gender pay equality in its organisation. Enforcement measures may be included in the regulations for employers that fail to comply with the requirements and it is expected to be an annual reporting duty. As such, employers will be expected to demonstrate a clear commitment to these plans and provide updates on their progress, moving beyond mere compliance to demonstrable change.

On the race and disability pay gap:

The proposed Equality (Race and Disability) Bill represents a significant development towards a more transparent and accountable pay landscape. Announced in the 2024 King’s Speech and the subject of a consultation in 2025, the Bill would require large employers (those with more than 250 employees) to report ethnicity and disability pay gaps, building on the gender pay gap regime introduced in 2017. The expansion of reporting requirements reflects growing recognition that meaningful progress on workplace equality can only be achieved when data is available across as many protected characteristics as possible. 

On equal pay:

The consultation document on the Equality (Race and Disability) Bill also proposes extending equal pay protection to ethnic minority and disabled employees. Combined with enhanced transparency on ethnicity and disability pay gaps, this aims to reduce structural disparities that persist despite existing anti‑discrimination law. Government briefings emphasise that mandatory disclosure will help employers identify pay barriers and reduce opportunities for opaque pay practices. No timescale has been set for the text of the draft Bill, though it is expected in 2026.  

There are various other proposals from the UK government which should assist employees in understanding an employer’s approach to pay. In April 2025, for example, the government issued a call for evidence around pay equality and transparency. The measures suggested include a proposed ban on employers asking job applicants about their previous or current pay during the recruitment process, a requirement to provide the salary or salary range for a job prior to interview (similar to the position under the PTD which requires salary information to be included in job adverts); and a requirement that employees be provided with information on their pay level and how their pay compares to those doing the same role or work of equal value. 

Together, these measures mark a shift from reactive enforcement to proactive organisational accountability. We anticipate that these measures are likely to lead to increased workforce claims against employers who are suspected of falling short of their obligations.