As part of the UK government’s proposed reforms to employment law (including the Employment Rights Bill currently making its way through parliament), the government launched a number of consultations in the Spring, including one on the extension of gender pay gap reporting to cover ethnicity and disability pay gap. Most recently, the government has also opened a “call for evidence” about wider potential reforms to equality law.

One of the ideas this call for evidence contemplates is the introduction of increased pay transparency obligations for UK employers.

What is a “call for evidence” and how seriously should we take it?

The call for evidence should be distinguished both from the Employment Rights Bill (which is about to be approved by parliament) and the consultation on ethnicity and disability pay gap reporting, as a call to evidence is much less concrete – it is not a formal consultation about firm proposals but rather an opportunity for the government to explore options and build an evidence base before deciding whether to bring forwards any solid proposals.

The government is simply asking people to give their views on the impact of introducing pay transparency measures. We anticipate that a further consultation process would be required before the government introduced any such pay transparency measures.

What is the government contemplating?

Specific measures to improve pay transparency suggested in the call for evidence include obligations on employers to:

• publish salary ranges in job advertisements;
• avoid asking candidates about salary history;
• sharing pay structures and progression criteria with employees;
• provide employees with pay comparisons to similar roles; and 
• proactively identify and address equal pay breaches.

“Pay” would include bonuses.

Similarities with the EU Pay Transparency Directive

The first four bullet points above are very similar to the obligations on European Union-based employers set out in the EU Pay Transparency Directive, although the definition of pay may not be as wide as under the Directive.

Next steps

The government has said that it will introduce the ethnicity and disability pay gap reporting via the Equality (Race & Disability) Bill in the Autumn. Given the speculative nature of this call for evidence, we think it is unlikely that any additional pay transparency measures will be in that Bill, but we will continue to monitor the position and keep clients up to date.

If you would like to respond to the call for evidence, please see: Equality law call for evidence - GOV.UK. The consultation will close at 11:59pm on 30 June 2025.

Your contacts

At Deloitte, we understand that navigating the demands and complexities of pay equity and transparency can be daunting. Our proposition is designed to help you overcome this challenge and achieve your goals. Our aim is to enable you to pay employees equitably and help you demonstrate that you are doing so.

With our deep multi-disciplinary expertise in reward, employment law, technology & analytics, and behaviour change, we are well-placed to be your trusted partner on this journey. Get in touch to discuss your challenges and needs.

Kathryn Dooks, Partner, Deloitte Legal, 020 7303 2894

Deepinder Lamba, Partner, Deloitte Global Employer Services, 020 7007 2689