COMPLIANCE
3. Eventually include those with 250–499 employees. This phased approach allows smaller organisations time to improve their data collection and analysis systems, boost disclosure rates and learn from the experiences of larger employers. The CIPD also recommends that after the initial phase, the Government commissions an evaluation of the first cohort of employers. This would help identify best practices and lessons that can be shared with subsequent groups, ensuring a smoother transition and more effective reporting. Avoiding a rushed rollout The CIPD has expressed concern that a rushed implementation could lead to poorly executed reporting and missed opportunities for meaningful change. Employers are already grappling with rising employment costs 4 , economic uncertainty and new legislative requirements from both the Employment Rights Bill 5 and the Equalities Bill. Introducing EDPR for all large employers at the same time could dilute its impact and reduce the attention it receives. Instead, a phased approach gives organisations the breathing space they need to prepare. It allows time to improve HR information systems, increase employee confidence in disclosing personal data and develop internal capabilities for analysing and interpreting pay data. Equality action plans: turning data into action Data alone won’t drive change. That’s why the CIPD supports the proposal for employers to publish equality action plans alongside their pay data. These plans should be clear, data- driven and focussed on measurable outcomes. They should also be verified by a senior HR professional, such as a Chartered Fellow of the CIPD, who has a broad understanding of the links between pay, recruitment, development, work design and talent management. Initially, this requirement should apply to organisations with 1,000 or more employees, before gradually extending to those with 500-999 and eventually 250-499 employees. Action plans should be uploaded to the appropriate pay reporting websites, either directly or via a web link, ensuring transparency and public accountability.
Importantly, these plans should align with the upcoming legal requirement for all large British employers to publish an equality plan focussed on reducing the gender pay gap and supporting female employees through the menopause, due to take effect in April 2027. Supporting employers for success To help employers meet these new requirements, the CIPD recommends that the Equality and Human Rights Commission be given the responsibility and resources to monitor compliance, provide templates and training and offer sector-specific guidance. This support will be crucial in helping organisations navigate the complexities of EDPR and develop meaningful action plans. Verification by a HR professional will also help build public confidence in the process and ensure consistency across sectors. The role of pay professionals For pay and reward professionals, EDPR presents both a challenge and an opportunity. We’re uniquely positioned to: l ensure accurate and consistent pay data l collaborate with HR teams to analyse disparities l support the development of fair and transparent pay structures l communicate pay policies clearly to employees. Our expertise in data management and compliance makes us key players in the successful implementation of EDPR. By engaging with this agenda, we can help our organisations to not only meet their legal obligations but also to build a more inclusive and high-performing workplace.
in the private sector, include salary details in job adverts, explain how pay decisions are made or communicate how pay structures are shaped. Public and voluntary sector organisations perform better in this regard, particularly in outlining pension contributions. But overall, there’s significant room for improvement. We can help lead the way by advocating for greater openness and fairness in pay practices. We can support our organisations in developing transparent pay frameworks, communicating pay policies effectively and ensuring pay and reward decisions are based on robust evidence, data and clear principles. Looking ahead Over the coming months, pay and reward professionals have a vital role to play in preparing for EDPR. This includes: l reviewing and improving data systems l encouraging employee disclosure l collaborating with HR teams l supporting the development of equality action plans. EDPR is a chance to build a fairer, more inclusive workplace. It’s an opportunity to use data to drive change, improve trust and unlock the full potential of our workforces. While the Government has its plan to ‘Make Work Pay’, EDPR is one of our key opportunities to help ‘Make Pay Work’, not only in terms of the organisation, but also for its employees. n Links corner 1. Equality (Race and Disability) Bill: mandatory ethnicity and disability pay gap reporting: https://ow.ly/ gBPE50XwPNM 2. CIPD consultation response: Equality (Race and Disability) Bill: mandatory ethnicity and disability pay gap reporting: https://ow.ly/LxBO50XwPQC 3. CIPP consultation response: Equality (Race and Disability) Bill: mandatory ethnicity and disability pay gap reporting: https://ow.ly/sszS50XwPT0 4. Labour Market Outlook: https://ow.ly/ WKBI50XwRhA 5. Timetable of employment law changes in the UK: https://ow.ly/ vRUu50XwRlE 6. CIPD consultation response: Equality Law: https://ow.ly/7QIn50XwRwz 7. Equality Law call for evidence: https:// ow.ly/2ZVP50XwRzh 8. Pay, performance and transparency 2024: https://ow.ly/oo9o50XwRCG.
The bigger picture: pay transparency as a business imperative
As the CIPD has highlighted in its recent response 6 to the Office for Equality and Opportunity’s Equality Law call for evidence 7 , this agenda is about more than just compliance. It’s also about driving better people decisions and unlocking the growth potential of the workforce and economy. Pay transparency, when done well, can improve employee trust, attract and retain top talent, foster inclusive organisational cultures, enhance business performance and contribute to wider economic growth. Yet, CIPD research 8 reveals a striking lack of pay transparency across many organisations. Few employers, especially
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| Professional in Payroll, Pensions and Reward |
Issue 116 | December 2025 - January 2026
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