Further to its National Disability Strategy published in July 2021, the Government is now consulting until 25 March 2022 on the case for mandatory workforce reporting on disability by large employers (with 250 or more employees).
Views are sought from employers and disabled employees on the current voluntary framework and how reporting could be increased, either voluntarily or through imposing mandatory requirements, in order to support the cultural changes required to build a more inclusive society and reduce the disability employment gap.
The consultation document notes that awareness of the voluntary framework appears low – CIPD research in April 2021 found that only 21% of respondents were aware of the framework and of these only 37% had implemented at least part of it. The voluntary framework encourages collection and publication of a range of information to contextualise the percentage of workforce considering themselves disabled, including policies for recruitment and retention of disabled people, the availability and take up of support offered, workplace adjustments made, pay and progression data, employee engagement levels, mental health training and wellbeing assessments. The consultation seeks evidence as to the awareness and usefulness of this framework.
The consultation also asks what data employers currently collect, suggesting possibilities which may indicate the types of information the Government is considering mandating. These include the proportion of disabled staff in the whole workplace and split by job level, types of disability, proportion of staff requesting reasonable adjustments, and data showing the disability breakdown of use of career progression schemes, pay and performance ratings.
The rest of the consultation seeks views on the benefits and barriers to voluntary or mandatory disability workforce reporting, how a mandated approach to reporting might be implemented in practice, and if there are alternative approaches that could also be taken to enhance transparency and increase inclusive practices.
Employers wishing to respond can do so here. The Government has indicated that it expects to publish its response to the consultation by 17 June 2022, a relatively tight timetable which perhaps suggests that it aims to include provisions for mandatory reporting (if this is the outcome of the consultation) in the long-awaited Employment Bill – and that this Bill may finally surface in 2022.