Corporate report

Ethnicity pay gap report: 1 April 2023 to 31 March 2024

Published 28 March 2025

Executive summary

This report sets out the Competition and Market Authority’s ethnicity pay gaps (EPG). Unlike gender pay gap reporting, for which there is a statutory requirement to report, ethnicity pay gap reporting is completed on a voluntary basis. The CMA has reported on EPG using guidance set out by the by the Department for Business and Trade (DBT) and the Commission on Race and Ethnic Disparities (CRED).

Since 2023 there have been the following changes in the CMA’s EPG:

• the mean ordinary EPG (all ethnic minority groups) has reduced from 25.8% to 23.5%
• the median ordinary EPG (all ethnic minority groups) has reduced from 31.1% to 25.8%
• the mean bonus EPG (all minority groups) has reduced from 45.0% to 35.8%
• the median bonus EPG (all minority groups) has reduced from 5% to 0.0%

Ordinary EPG

We have continued to see a reduction in our mean pay gaps across all ethnic minority groups. Our median pay gaps have also decreased for all groups, except Black backgrounds, where we have seen an increase of 3.6 percentage points (ppt). We have a small representation of employees from a Black background, and in 2023 to 2024, 14% left the organisation, which contributed to increasing our gap.

Bonus EPG

We have also seen a reduction in our mean bonus gaps, across all ethnic minority groups, except Black backgrounds, where we have seen a 2.2ppt increase. Our median gaps have reduced to 0% for all groups. This is likely to be mainly driven by the approach to non-consolidated pay where an organisational award was paid to all eligible staff at grades not in the Senior Civil Service (SCS), rather than linking pay to individual performance ratings. 69.1% of all ethnic minorities received a bonus in comparison to 67.9% of White employees who received a bonus.

Where a bonus was paid at the SCS level, ethnic minorities received a higher mean and median bonus than White employees, which has contributed to the reduction in bonus gaps.

Targeted action

We have continued to deliver against our Equality, Diversity and Inclusion Strategy 2020 to 2024 and this report outlines actions we have taken in this reporting period to reduce the EPG. Our work is aligned with continuing to improve our representation of ethnic minorities, particularly at a senior level and using our data to inform our actions.

Introduction

There is currently no statutory requirement to publish ethnicity pay gaps (EPG), but there have been a series of guidance documents issued in 2021 and 2022 with the latest issued on 17 April 2023, by the Department for Business and Trade (DBT). The guidance outlines how to measure, report on and address any ethnicity pay differences within the workforce.  We have aligned with this DBT guidance, providing a comprehensive analysis and explaining what is driving our pay gaps as well as the steps that we are taking to reduce them.

We have also aligned with the recommendations set out by the Commission on Race and Ethnic Disparities (CRED) in 2021, by presenting outcomes for specific minority ethnic groups. We have also aligned with the October 2024 Cabinet Office guidance on ethnicity groups and preferred style of writing, to use the following throughout this report:

• Asian (including Indian, Pakistani, Bangladeshi, Chinese, and other Asian background)
• Black (including Black Caribbean, Black African and any other Black, Black British or Caribbean background)
• Mixed (including any mix of the above categories, including white)
• Other: where staff have disclosed that their ethnicity does not fall into the above categories or any of the white ethnic groups.
• White (English, Welsh, Scottish, Northern Irish or British, Irish, Gypsy or Irish Traveller, Roma, Any other White background)
• not reported: where employees have not recorded their ethnicity, including prefer not to say

It is acknowledged that there may be differences in outcomes between groups within the above categories (for example, Indian and Chinese). However, due to the sample sizes, the outcomes are reported within the above categories. In addition, where analysis by each minority ethnic group would break data into small sample sizes, for example, joiners and leavers data, outcomes have been reported as a comparison between all minority ethnic groups and White or expressed as percentages.

The new guidance recommends that employers present and consider a range of calculations broken down by ethnicity categories and therefore the pay measures contained in this report are:

• ordinary ethnicity pay gaps, including the mean and median for each ethnic group
• bonus pay gaps, including the mean and median for each ethnic group
• the proportion of each ethnic group who received a bonus
• a breakdown of the representation of ethnic groups across the CMA by Grade and Pay Quartile

The EPG is a measure of the difference between ethnic groups’ average earnings across an organisation or the labour market over a period, regardless of role or seniority. It is not a like-for-like comparison of employees of different ethnicities.

A pay gap is not the same as unequal pay. Unequal pay means that employees performing equal work, or work of equal value, are not receiving equal pay. It is unlawful to discriminate either directly or indirectly against employees and people seeking work because of their race, including ethnicity; this includes paying an employee less or giving them terms and conditions, which put them at a disadvantage because of their race.

The CMA supports the fair treatment and reward of all staff irrespective of ethnicity.

Organisational context

The CMA is an independent non-ministerial UK Government department and is the UK’s principal competition and consumer protection authority. We help people, businesses and the UK economy by promoting competitive markets and tackling unfair behaviour.

Our Equality, Diversity and Inclusion Strategy 2020 to 2024 describes how equality, diversity and inclusion are essential to the way that we operate, both as the UK’s competition authority and as an employer. To deliver our strategy, we have developed a series of action plans. Our final action plan (2022 to 2024) is focussed on 5 key themes:

• recruitment and ‘growing our own’
• career progression and development
• improving senior representation
• pay and reward
• promoting a culture of inclusivity

We have published reviews of our progress against our strategy, objectives and action plans in April 2021, September 2022 and October 2024.

The highlights of what has been delivered through this action plan and how it has supported reducing our pay gaps can be found in the action planning section of this report.

Organisational structure

The number of people (FTE) employed by the CMA at 31 March 2024 was 1,087.7.

For the purpose of the ethnicity pay report though:

• 1,050 employees have been established to be in scope for calculation to determine the mean and median ordinary pay gaps, meaning in receipt of full pay on 31 March 2024
• 1,084 employees have been established to be in scope for the calculation to determine the gender mean and median bonus gaps, covering the 12-month period between 1 April 2023 and 31 March 2024

Of the 1,050 employees in scope for the ordinary pay gaps, 28 staff were based in Belfast, 26 in Cardiff, 16 in Darlington, 94 in Edinburgh, 837 in London and 49 in Manchester. Of note, the CMA increased its headcount by 303, 289 in grades AO to G6 and 14 in SCS grades as it expanded to take on new responsibilities and powers, particularly in Digital Markets. 

The breakdown of grades at 31 March 2024 and percentage of each ethnic group are shown in the following table.

Figure 1: Break down of percentage of colleagues in each ethnicity category for each grade

Civil Service grade	Total staff	Asian	Black	Mixed	Other	White	Not reported
AO	34	38.2%	8.8%	2.9%	0	41.2%	8.8%
EO	74	24.3%	12.2%	5.4%	0	54.1%	4.1%
HEO	189	20.1%	8.9%	3.7%	1.1%	59.8%	6.4%
SEO	97	11.3%	7.2%	8.3%	1.0%	72.2%	0
Grade 7	283	14.1%	3.9%	3.5%	1.1%	73.1%	4.2%
Grade 6	234	8.1%	1.7%	3.9%	2.6%	74.4%	9.4%
SCS PB1	112	5.4%	0	0	0.9%	85.7%	8.0%
SCS PB2 and PB3	27	0	0	0	0	92.6%	7.4%
Total	1050	13.8%	4.9%	3.7%	1.2%	70.4%	6.0%
Combined	N/A			23.6%		70.4%	6.0%

The following tables show the joiners and leavers in the reporting period

Figure 2: Joiners profile by ethnicity and grade between 1 April and 31 March 2024

(Grouped due to small sample sizes)

Civil Service grade	Total staff	Ethnic minority	White	Not reported
AO	25	10	13	2
EO	33	12	20	1
HEO	83	28	52	3
SEO	52	11	41
Grade 7	62	19	42	1
Grade 6	34	7	27
SCS PB1	11	1	10
SCS PB2 and PB3	3	0	3
Total	303	88	208	7

Figure 3: Leavers Profile by ethnicity and grade between 1 April and 31 March 2024 (Grouped due to small sample sizes)

Civil Service grade	Total staff	Ethnic minority	White	Not reported
AO	18	11	6	1
EO	10	5	5
HEO	24	10	14
SEO	11	3	7	1
Grade 7	38	13	24	1
Grade 6	18	3	12	3
SCS PB1	7	0	7
SCS PB2 and PB3	4	1	2	1
Total	130	46	77	7

Ethnicity pay gap report

It should be noted that the following ethnicity pay gap statistics have not included the additional non-consolidated one-off payments made to civil servants in 2023 of £1,500. The payments were not considered to fall within the scope of pay for the purpose of calculations and in any event were made outside the relevant pay period of March 2024 for the main pay gap statistics and are therefore excluded from those calculations. The payment has also been excluded from the bonus pay gap statistics as the payment was not by way of a bonus for these purposes and to treat it as such would serve to mask the true underlying bonus pay gap figures for 2023 to 2024.

Ordinary pay

Ordinary pay, expressed as hourly pay, is used to calculate the mean and median ethnicity pay gaps. Ordinary pay includes basic pay, any allowances and any bonus payments made in March 2024. Salary sacrifice amounts are deducted from this value.

The calculation for the mean and median ordinary pay only includes ‘full pay relevant’ employees, as described in section 1.

The ethnicity pay gap calculations are based on the number of individual employees and not on full time equivalents. This means that each part-time employee counts as one employee.

The following table shows the 2023 to 2024 mean EPG and median EPG in the CMA.

Figure 4: Mean and median Ordinary EPG for the last 3 reporting periods

Ethnic group	2023 to 2024 mean pay gap	2023 to 2024 median pay gap	2022 to 2023 mean pay gap	2022 to 2023 median pay gap	2021 to 2022 mean pay gap	2021 to 2022 median pay gap
Asian	23.6%	25.8%	25.9%	32.5%	24.1%	27.8%
Black	32.6%	36.3%	33.4%	32.7%	36.7%	35.3%
Mixed	19.8%	19.4%	27.1%	28.2%	26.5%	23.6%
Other	-2.31%	-15.4%	-14.7%	-26.7%	10.7%	4.4%
All ethnic minority groups	23.5%	25.8%	25.8%	31.1%	26.4%	27.3%

The table below shows the percentage point differences for each category for both mean and median. We have seen a reduction in the mean pay gaps for all categories and a reduction in the median pay gaps for all categories except black, where we have seen a 3.6ppt increase.

Figure 5: Percentage point difference for ordinary mean and median EPG for all ethnic groups

Ethnic group	2023 to 2024 mean percentage point difference	2023 to 2024 median percentage point difference
Asian	2.3	6.7
Black	0.8	3.6
Mixed	7.3	8.8
Other	-12.4	-11.3
All ethnic minority groups	2.3	5.3

Bonus pay

Bonus pay, which is also calculated as mean and median, is based on bonus payments paid to staff throughout the 2023 to 2024 financial year.

This calculation may include employees who are not ‘full pay relevant’ employees but will not include employees who left the CMA before 31 March 2024.

At the CMA, usually bonus pay includes any performance related pay (PRP). These are payments based on performance management outcomes for the previous financial year. In the case of staff in grades AO to Grade 6, these payments are negotiated annually with our recognised trade unions.

For the 2023 to 2024 pay award year, there continued to be no link between individual performance and pay to reflect achievement in the 2022 to 2023 performance year. Instead, in recognition of the continuing high performance across the CMA in that period, we paid a flat non – consolidated payment of £1,125 to all eligible staff in the January 2024 payroll. This award was included in the bonus payments made during the 2023 to 2024 financial year and is therefore included in the bonus gap calculations.

For SCS staff, there are separate arrangements which are centrally set by government each year. SCS bonuses are included in the bonus calculations and is the biggest contributor to the increase in bonus gap.

Bonus GPG

The following tables show the 2023 to 2024 mean bonus gap and the median bonus gap in the CMA for the past 3 years, and the differences between the latest 2 years.

Figure 6: Mean and Median Bonus EPG for all ethnic minority categories over the last 3 reporting periods

Ethnic group	2023 to 2024 mean bonus gap	2023 to 2024 median bonus gap	2022 to 2023 mean bonus gap	2022 to 2023 median bonus gap	2021 to 2022 mean bonus gap	2021 to 2022 median bonus gap
Asian	34.01%	0%	43.10%	10.00%	45.50%	10.30%
Black	49.53%	0%	47.30%	5.00%	54.20%	15.00%
Mixed	43.89%	0%	48.80%	5.00%	44.00%	-3.70%
Other	-28.53%	0%	42.90%	5.00%	48.90%	10.30%
All ethnic minority groups	35.8%	0%	45.00%	5.00%	47.40%	10.30%

Figure 7: Mean and median percentage point difference for each ethnic group between 2023 to 2024 and 2022 to 2023 reporting periods

Ethnic group	2023 to 2024 mean percentage point difference	2023 to 2024 median percentage point difference
Asian	9.1	10
Black	2.23	5
Mixed	4.9	5
Other	-14.37	5
All ethnic minority groups	9.2	5

As outlined, we have seen a reduction in all mean bonus gaps except Black backgrounds, where there has been a 2.23ppt increase. Our median bonus gaps have all reduced, and this is now at 0% for all categories.

Percentage of all ethnic groups receiving a bonus in 2024

68.7% of all employees received a bonus, the following table is a breakdown of ethnic groups that received a bonus. 69.1% of all ethnic minorities received a bonus in comparison to white employees where 67.9% received a bonus. To be eligible staff needed to be in the organisation at the end of September 2023. New starters between 1 January and 31 March received a quarter payment.

Figure 8: Proportion of staff in receipt of bonuses

Ethnic group	Percentage
Asian	67.4%
Black	70.9%
Mixed	75.0%
Not reported	79.2%
Other	52.9%
White	67.9%

Pay quartiles

The Pay quartiles show the proportion of ethnic minority groups across each of the defined pay quartiles. Quartiles are calculated through ranking all salaries from the highest to the lowest paid, and dividing the list into quarters

Figure 9: Distribution of ethnic minority groups across the pay quartiles

The pay quartile distribution shows the proportion of all ethnic minorities is lower than White employees across all quartiles. There is a higher representation of ethnic minorities in quartile 1 (42.2%) which represents our junior grades. The lowest representation is in the upper quartile where 21.1% of ethnic minorities are represented, recognising that this this is also the quartile with the highest proportion of employees who have not reported their ethnicity.

Ordinary EPG analysis

In 2023 to 2024 we reduced the mean pay gaps for all categories and we have reduced the median pay gaps for all categories except Black, where we have seen a 3.6ppt increase.

Figure 9: Ordinary EPG for the last 3 years

Ethnic group	2023 to 2024 mean pay gap	2023 to 2024 median pay gap	2022 to 2023 mean pay gap	2022 to 2023 median pay gap	2021 to 2022 mean pay gap	2021 to 2022 median pay gap
Asian	23.6%	25.8%	25.9%	32.5%	24.1%	27.8%
Black	32.6%	36.3%	33.4%	32.7%	36.7%	35.3%
Mixed	19.8%	19.4%	27.1%	28.2%	26.5%	23.6%
Other	-2.31%	-15.44%	-14.7%	-26.7%	10.7%	4.4%
All ethnic minority groups	23.5%	25.76%	25.8%	31.1%	26.4%	27.3%

The primary reason likely to have contributed to the ordinary pay gaps decreasing overall is the slight increase in representation of ethnic minorities, particularly at grades 6 and 7 and maintaining representation of ethnic minority colleagues at SCS at 5.4%

• Asian from 10.6% to 22.2%
• Black from 3.5% to 5.6%
• Mixed from 3.1% to 7.4%
• Other from 1.1% to 3.7%

The increase to the median for Black ethnic minority colleagues can be attributed to the percentage of leavers that were from a Black minority ethnic background (14%).

Whilst we have reduced our gap, we know that the following is continuing to contribute to having pay gaps.

1 . We know that there is a higher representation of staff from ethnic minority backgrounds at the junior grades, as well as lower representation at the higher grades, particularly at SCS.

2 . Whilst we welcomed 29% of new starters from ethnic minority backgrounds, 35.4% of all leavers were from an ethnic minority background, impacting our overall representation.

• Asian reduction by 0.3ppt
• Black increase by 0.3 ppt
• Mixed reduction by 0.3 ppt
• Other increase by 0.2 ppt
• White increase by 1.9 ppt
• all ethnic minorities reduction by 0.2ppt

3 . Digital, Data and Technology (DDaT) allowances were introduced in the 2020 to 2021 financial year. These allowances are paid to eligible DDaT roles – defined by the Government Digital Service (GDS) who centrally own the framework. The number of employees from ethnic minority backgrounds in receipt of DDaT allowances has remained the same at 20%. Ethnic minority employees are represented in these roles at G6 to G7 only.

Ordinary pay gaps by grade

Looking at the mean and median gender pay gaps by grade, the differences are considerably smaller than the overall figures for the CMA in 2023 to 2024 as shown below in Figure 4 below.

Figure 10: Ordinary mean and median EPG by Grade

Civil Service grade	Mean pay gap 2023 to 2024	Mean pay gap 2022 to 2023	Median pay gap 2023 to 2024	Median pay gap 2022to 2023
AO	-0.33	2.0	0.0	3.7
EO	2.70	6.2	0.0	5.6
HEO	-0.74	0.9	0.0	0.1
SEO	-0.10	3.2	-0.23	2.7
Grade 7	1.07	1.4	1.46	1.2
Grade 6	0.38	0.2	-1.43	-2.2
SCS PB1	0.99	0.2	0.47	2.6
SCS PB2 and PB3	N/A	N/A	N/A	N/A

Ethnic groups have been combined

The table above shows that we have reduced both our mean and median pay gaps across all grades since the 2022 to 2023 reporting period. Where there is a negative percentage, this means that the ordinary pay for an ethnic minority group is higher than the white comparator group. The most significant mean reduction is at grade EO. The most significant median reduction is at grade AO, EO, SEO. The primary reason for the variation across grades is the impact of new starters joining the organisation.

Bonus EPG analysis

In 2023 to 2024, we have seen a reduction in all mean bonus gaps except Black backgrounds, where there has been a 2.23ppt increase. Our median bonus gaps have all reduced, and this is now at 0% for all categories.

Figure 11: Mean and Median Bonus EPG for all ethnic minority categories over the last 3 reporting periods

Ethnic group	2023 to 2024 mean bonus gap	2023 to 2024 median bonus gap**	2022 to 2023 mean bonus gap	2022 to 2023 median bonus gap	2021 to 2022 mean bonus gap	2021 to 2022 median bonus gap
Asian	34.01%	0%	43.10%	10.00%	45.50%	10.30%
Black	49.53%	0%	47.30%	5.00%	54.20%	15.00%
Mixed	43.89%	0%	48.80%	5.00%	44.00%	-3.70%
Other	-28.53%	0%	42.90%	5.00%	48.90%	10.30%
All ethnic minority groups	35.8%	0%	45.00%	5.00%	47.40%	10.30%

At the CMA, usually bonus pay includes any performance related pay (PRP). These are payments based on performance management outcomes for the previous financial year.

For performance year 2023 to 2024, it was agreed that there would not be a link between performance ratings and non-consolidated payments. A flat rate organisational award was paid instead, with colleagues joining in the last quarter of the performance year receiving a quarter payment. 

For SCS staff, there are separate arrangements which are centrally set by government each year. SCS colleagues continue to receive bonus based on their individual performance. Whilst there has been an increase in the representation of women at SCS level, they may have received lower performance ratings due to their time in role, and therefore lower average bonuses would contribute to the bonus gap.

The reduction in the mean bonus gap can partly be attributed by the approach to pay where in 2023 to 2024, a flat organisational award was paid to all eligible staff, rather than linking pay to performance. 69.1% of all ethnic minorities received a bonus in comparison to white employees where 67.9% received a bonus.

SCS colleagues continue to receive bonus based on their individual performance. Where bonus was paid at SCS, ethnic minorities received a higher mean and median bonus than white employees, which has contributed to the reduction in bonus gaps.

Bonus gaps by grade

The median bonus EPG has reduced across grades AO, EO, HEO, and G7.  It has increased for grades SEO, Grade 6 and SCS PB1.  It is favourable to ethnic minorities in grades EO, HEO, grade 6 and SCS PB1.

Figure 12: Mean and median bonus EPG by grade

Civil Service grade	2023 to 2024 mean bonus gap	2022 to 2023 mean bonus gap	2023 to 2024 median bonus gap	2022 to 2023 median bonus gap
AO	16.67%	-68.0%	0.00%	-600.0%*
EO	-2.30%	8.3%	0.00%	12.2%
HEO	-1.79%	-12.9%	0.00%	5.3%
SEO	1.96%	-1.7%	0.00%	2.7%
Grade 7	0.55%	-4.9%	0.00%	-10.5%
Grade 6	-7.53%	1.9%	0.00%	9.5%
SCS PB1	-25.96%	10.4%	-21.84%	15.0%
SCS PB2 and PB3	N/A	-19.5%	N/A	-19.8%
All staff	35.8%	5.6%	0.0%	0.0%

Targeted action to reduce the ethnicity pay gap

To deliver the final 2 years of our Equality, Diversity and Inclusion Strategy 2020 to 2024, we launched a detailed action plan, following engagement with internal stakeholders. The initiatives in the plan are intended to make a wide-reaching impact on equality, diversity and inclusion at the CMA, including having an impact on our pay gaps.

Our Equality, Diversity and Inclusion Action Plan 2022 to 2024 is focussed on:

• recruitment and ‘growing our own’
• career progression and development
• improving senior representation
• pay and reward
• promoting a culture of inclusivity

Details of the full plan and the work that was delivered in 2023 to 2024 can be found in the annual report.

Impact of the plan on our pay gaps

Continuing to reduce our pay gaps is centred around improving our representation at a senior level and improving the pipeline of ethnic minority applicants across grades where there is underrepresentation.

Improving representation and leadership accountability

In support of our representation ambitions, we have scoped and agreed a holistic set of measures, incorporating Diversity Representation and Inclusion. This set of measures will enable us to hold ourselves and our leaders to account for the progress on inclusion, representation and closing our pay gaps.

Using our data to inform our actions

We already measure diversity in the CMA, but in addition to this, we have created a recruitment dashboard which enables us to see the diversity of our talent pipeline. It enables us to make more proactive decisions on how we improve the proportion of ethnic minority individuals that are applying to roles, being recruited, and thriving in the CMA.

We have also introduced diverse interview panels which includes gender and ethnically diverse panel composition. This ensures that different perspectives are considered, and candidates can visibly see representation, particularly at a senior level.

We regularly monitor and review performance outcomes across all ethnicities and where there are disparities, we work to address the root causes, to ensure equitable outcomes.

Our future plans

We will next report on EPG by March 2026, for the period of 1 April 2024 to 31 March 2025, and in that period, we will focus on delivering the following actions as we complete the work on our existing EDI strategy and action plans.

Committing to being a diverse and inclusive organisation

We will communicate to the organisation our ambitions for diversity representation, across women, ethnic minorities, black, disability and our Lesbian, Gay, Bisexual, Other (LGBO) community, for grades AO to G6 and SCS. The ambitions have been centrally set using the UK Census (2021) and we will track progress quarterly.

Reviewing our end-to-end recruitment process

It is important to us that we ensure our recruitment process is inclusive and therefore we will commission an external review of all our recruitment processes.

Retaining our staff

This is critical in maintaining our representation, and continuing to reduce our pay gaps, therefore we will continue to deliver our existing development programmes as well as review where we have any gaps to enable us to achieve our ambitions, and to improve representation, particularly in SCS roles.

EDI priorities 2025 to 2026

Our existing EDI strategy and plans expire at the end of March 2025, and therefore we will be starting work to refresh our objectives and priorities.

Declaration

We confirm that data reported by the CMA is accurate and has been calculated according to the methodology set out in the latest guidance by the Department of Business and Trade and mirrors the requirements of requirements pf gender pay gap reporting as set out in the Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017.