Open consultation

Annex B: Findings of the 2021 to 2022 Disability Workforce Reporting consultation

Published 18 March 2025

Introduction

The Disability Unit in the Cabinet Office ran a consultation on disability workforce reporting (DWR). It was open to respondents for 16 weeks between 16 December 2021 and 8 April 2022.

The consultation asked people for their views on data collection, transparency and the benefits and risks of reporting practices on disability in the workforce. It also asked for alternative suggestions to voluntary or mandatory workforce reporting to increase workplace inclusion and employment of disabled people.

The consultation was hosted on GOV.UK and available as an online survey via the Citizen Space portal. It was also available in a range of alternative formats, including: PDF, British Sign Language (BSL), Easy Read, large print, Braille and Welsh. Responses to the survey were also accepted via email and post. This report shares the analysis of the findings from the consultation survey on Citizen Space and in alternative formats.

A series of 7 roundtables involving a mix of people representing employer and employee perspectives were also held. The discussions at these roundtables have been analysed separately and considered alongside the findings of this report.

Methodology

Descriptive quantitative analysis was conducted on closed questions using the statistical software package R. Responses to all open questions were read in full by the research team. Responses were fully coded into an Excel-based codebook, which was used to develop the themes per question, and the overarching themes. The major themes are discussed in this report.

All responses were considered equally regardless of the mode of response. Responses from the Citizen Space survey all followed the same structure. Those responding by email often did not follow this structure, though covered many of the same topics. Email responses were considered under the questions that their comments pertained to, even if they did not follow this structure themselves. They have also contributed to the overarching themes.

Respondent characteristics

The consultation received 447 responses:

• 90% (404 responses) were submitted via online survey
• 10% (43 responses) were received by email or post

Out of the 447 responses:

• 26% (115 responses) were from an employer or employer representative organisation or network
• 72% (323 responses) were from an employee, or employee representative organisation or network, or other individual
• 2% (9 responses) were from a respondent representing both groups

Summary of findings

This section first sets out overarching themes found across questions. It then sets out the high-level findings across the 4 parts of the consultation itself.

Overarching themes

Whilst there was a wide mix of views represented across the responses received to all questions, some clear themes emerged.

Some of the overarching themes suggested potential positive impacts of DWR:

• representation: monitoring and making public the representation of disabled people in workplaces
• reasonable adjustments: assisting in identifying support needs and improving the provision of reasonable adjustments
• awareness: increasing the awareness and understanding of disability and disabled people in the workplace
• accountability: holding employers to account, and incentivising or pushing them to improve
• comparability: making it possible to compare employers and to benchmark

Some of the overarching themes sounded a note of caution, or suggested potential negative impacts of DWR:

• disclosure of disability: creating issues for disabled employees around the disclosure of their disability status, or amplifying existing issues of this kind. Issues included fears of (or actual) discrimination following disclosure, or lower quality data if fear of discrimination leads to non-disclosure
• lack of real impact: becoming a tick-box exercise, or not leading to the further action that is required from employers – responses also highlighted this reporting measure being insufficient on its own to determine whether or not an employer is inclusive, with narrative or context also being needed
• data protection: needing to have strong data security and protection measures in place, including suggestions that disability data should be captured anonymously

Headline findings related specifically to information gathered under the 4 headings in the consultation document can be found below.

Understanding the current landscape

Where an organisation collected disability data, the proportion of disabled people in the workforce was the most commonly collected information reported (96% of employer respondents and 73% of employee respondents said that their organisation collected this). 59% of employer respondents said that their organisation collects data on the proportion of disabled staff working at different levels in the organisation.

Nearly 90% of employer respondents used existing HR processes to collect information on disability in their workforce. The majority of employer respondents (54%) reported that this information had been collected for more than 5 years, with 34% collecting it for between 1 and 5 years. Over three-quarters of employer respondents (77%) said their organisations didn’t use the voluntary reporting framework.

The majority of employer respondents (61%) said that the cost to the organisation of collecting disability workforce data was ‘none or negligible’. A quarter of respondents said there was ‘some cost, but not a lot’.

The 3 most common uses of workforce data were to inform diversity and inclusion initiatives, to inform recruitment practices and to track progress on diversity and inclusion initiatives.

31% of respondents said that their employer or organisation published their disability workforce data externally.

The majority of employees (90%) stated that they strongly agreed or agreed that employers should collect workforce data.

Benefits and barriers to disability workforce reporting

When asked whether they thought that greater transparency on disability in the workplace led to more inclusive practices, 85% of employer respondents and 74% of employee respondents thought that it did. When asked to explain their answer, the most common theme amongst both employer and employee responses was that transparency leads to increased awareness and understanding of disability and the needs of disabled people, as well as to increased awareness and availability of support.

The majority of respondents felt that disability workforce reporting by large employers (250+ employees) should be mandatory (70% of employer respondents and 74% of employee respondents).

When asked about the benefits of voluntary reporting, the most common theme amongst employer responses was that because it’s a choice, voluntary reporting demonstrates a stronger commitment and is less likely to be a tick-box exercise. The most common response from employee respondents was that there were none.

When asked about the risks of voluntary reporting, the most common theme from both groups was that some or most organisations will not do it if it is voluntary, and that only organisations who have good numbers to report will do it.

On increasing the uptake of the voluntary reporting framework, employer respondents most commonly suggested that there is a need to increase employers’ awareness. The most common theme amongst employee responses was to say that it should be made mandatory.

The benefits to mandatory reporting most commonly identified by both types of respondent were that it:

• allows for complete, accurate and standardised data, allowing comparison and benchmarking
• could lead to increased support and opportunities for disabled employees and an increased awareness of disability

The most common risks identified were:

• it could be a tick-box exercise with no tangible impacts on improving inclusion
• concerns about employees not wanting to, or feeling forced to, disclose their disability status

The most common benefits of publishing the data identified by both employer and employee respondents were that it provides helpful information for disabled people when deciding where to work, and that it encourages employers to take action to support disabled employees. The risks most commonly identified by employer respondents were that low disclosure rates could distort the picture and the potential for reputational damage. Employees most commonly reported that there are no risks, or that it could be a tick-box exercise that doesn’t bring about the necessary changes.

Considerations if mandatory disability workforce reporting were to be implemented

87% of employers and 83% of employees strongly agreed or agreed that the proportion of employees identifying as disabled is a useful statistic to report. The most common theme from both types of respondent was that the data can be used to determine the representation of disabled people in the workforce. A further major theme was that it raises the profile of disability issues.

When asked what other statistics should be reported instead of or alongside the proportion of employees identifying as disabled, the most common suggestions were: impairment, reasonable adjustments, pay, job level, other protected characteristics and/or intersectionality, progression, and the proportion of disabled people in senior positions.

There was strong support for the use of standardised approaches to collecting disability workforce data if reporting becomes mandatory for large employers, with 95% of employers or employer representative organisations and 83% of employee or employee representative organisations strongly agreeing or agreeing. However, there was an almost equal split (40% to 50%) from employer and employee respondents on which of the 2 types of wording^{[footnote 1]} should be used when asking employees if they identify as being disabled.

Employers were asked what would help them to implement disability workforce reporting in consistent and effective ways. Responses included the need for toolkits and guidance, a free and simple reporting facility, a standard questionnaire and template and tools for communicating across the organisation.

Employees were asked what could help people feel comfortable to disclose. The most common theme was that the data should be anonymised, should be untraceable back to individuals or should be collected by a third party.

In terms of reporting and publishing workforce data, just over 60% of employers felt that central government should be the organisation that employers report to if disability workforce information were to be collected. The most common choice amongst employee respondents was a regulatory body (64% of respondents).

The majority of employers (88%) and employees (82%) said that large employers should publish organisation-level disability workforce statistics. 76% of employers felt that the employer should publish their workforce statistics themselves, with 44% feeling that it should be central government that publishes this data. Employees however had a greater split in their responses, with 55% saying a regulatory body and 54% saying the employer.^{[footnote 2]}

Alternative approaches

Employers and employees were asked a final question, on what alternative to workforce reporting could increase the inclusion and employment of disabled people. The suggestions received in this section were very varied, but some broad themes did emerge.

The main theme in responses from both employees and employers was improving the support and reasonable adjustments available to disabled employees. Responses from both employees and employers also included a significant theme around improving the accessibility and inclusiveness of recruitment practices. Some employer and employee respondents also highlighted the importance of disabled staff networks, disability champions and sharing success and best practice.

Some employer respondents said that there was a need to improve and promote the Disability Confident scheme, and to make improvements to data and reporting. Some employer respondents also highlighted the need to listen to and engage with disabled people, including collecting feedback and giving disabled employees opportunities to have their voices heard.

The need to improve awareness and attitudes around disability was a common theme among employee responses. This included focusing on strengths not weaknesses and using the social model of disability^{[footnote 3]}, normalising disability and reducing stigma, and better understanding of specific impairments. Employee responses also included themes on education and training for employers and incentivising (for example, subsidies), monitoring (for example, audits or an ombudsman) and enforcement (for example, sanctions and tougher laws). None of these themes were significant themes in employer responses.

Next steps

The findings of this consultation will now be considered by the government alongside its commitment to introduce mandatory disability pay gap reporting for large employers. All of the feedback and information gathered through this consultation, as well as via the roundtables, will feed into the government’s thinking on how best to improve employment opportunities and workplace inclusion for disabled people.

1. The question asked respondents for their preference on 2 suggested forms of wording. These were: 1) ‘Do you consider yourself to have a disability or a long-term health condition (mental health and/or physical health)?’ 2) ‘a. Do you have any physical or mental health conditions or illnesses lasting or expected to last 12 months or more? and b. Does your condition or illness\do any of your conditions or illnesses reduce your ability to carry out day-to-day activities?’ ↩

2. Respondents could select multiple options to this question. ↩

3. For an explanation of the social model of disability, see: https://www.scope.org.uk/social-model-of- disability ↩