The UK’s Office for Equality and Opportunity has opened a consultation on how it can deliver a comprehensive reform of the country’s equal pay framework across England, Scotland, and Wales.
The consultation opened on 14 July 2026 and will remain open for feedback until 27 October 2026 at 5 p.m. GMT. It is open to anyone with an interest in or connection to these issues, including employers, trade unions, public sector bodies, women’s sector, race, and disability stakeholders, legal experts and practitioners, and individuals with lived experience of pay and reward.
Why Is the UK Reforming Its Equal Pay Framework?
The government has identified several shortcomings in the current equal pay system that it believes the reform should address:
- A failure to provide the data and tools needed to reliably and efficiently identify discriminatory pay practices
- An enforcement structure that places too much of the burden on individuals rather than on systemic accountability
- Incentives that encourage disputes over minor procedural details, multiplying time, stress, and expense for all parties
- Insufficient protection for groups who need it most, including disabled employees, employees from ethnic minority groups, and outsourced workers
What Is the Government’s Proposed Approach?
The consultation document outlines a two-phase approach to reform:
- Phase 1 focuses on fixing the current system through improvements to pay transparency and enforcement.
- Phase 2 focuses on filling gaps in the current system to establish an effective right to equal pay for all — including ensuring that pay discrimination on the basis of race and disability is taken as seriously as pay discrimination on the basis of sex, and requiring employers to take all reasonable steps to uphold pay equality in their contractual arrangements.
The consultation poses 82 questions in total. Phase 1, which centers on pay transparency and enforcement, is where most of the near-term employer impact is likely to be concentrated.
What Pay Transparency Changes Are Being Proposed?
Pay information in job adverts. In a proposal that would align the UK more closely with the EU’s approach to pre-employment transparency, the consultation proposes a statutory requirement for all employers to publish pay information in job adverts. Where no job advert exists, employers would need to provide this information to candidates in writing before the interview. The government has indicated it wants to keep the administrative burden low and is not proposing new reporting requirements. It is still assessing what level of detail beyond a basic salary figure, if any, should be required. The consultation specifically asks respondents whether they agree with the proposal and what level of information — a pay range, a specific salary, or a benchmark rate — would be proportionate.
Strengthened pay audit and job evaluation orders. For employers found in breach, or under reasonable suspicion, by a newly proposed Equal Pay Regulatory and Enforcement Unit, the consultation proposes narrowing the current exceptions that allow tribunals discretion over whether to order an equal pay audit. Under the proposal, a tribunal would be required to order an audit unless the employer had already completed an audit meeting the requirements within the prior three years. Tribunals would also be required to order implementation of a non-discriminatory job evaluation scheme where none currently exists. The consultation asks whether respondents agree with narrowing the list of exceptions in this way.
Reinstated statutory questionnaire. The consultation proposes reintroducing a standard questionnaire specific to pay discrimination disputes, in narrowed form, restoring a procedure that was repealed in 2013. Use of the questionnaire would be optional, but a court or tribunal could draw an adverse inference from a failure to respond, or from an evasive or equivocal answer. The intent is to help claimants identify an appropriate comparator or obtain information about pay components they might not otherwise have access to, with accompanying guidance to simplify the process for employers. The consultation seeks feedback on what specific questions the questionnaire should include and how to keep the procedure efficient.
What Broader Feedback Is the Government Seeking From Employers?
Beyond the specific proposals above, the consultation asks employers to weigh in on the practical impact of the reforms as a whole:
- How employers might change recruitment practices, pay, or conditions if these proposals are implemented
- What costs — wage, administrative, or legal — employers anticipate facing
- Whether any of the proposals would take more than a year to implement, and why
- What other changes to pay transparency employers would recommend
- What guidance would improve clarity around when an employer can lawfully pay people differently for equal work, particularly regarding the material factor defense
- The anticipated cost and operational impact of the proposed enforcement changes
What Should Employers Do Now?
Employers with operations in England, Scotland, or Wales have a meaningful window to shape this reform before it takes final form. Because the consultation covers both transparency obligations and enforcement mechanics, the practical response for most organizations should include the following steps:
- Review current job evaluation and pay audit practices against the proposed requirement for mandatory tribunal-ordered audits
- Assess job posting practices in anticipation of a potential statutory requirement to disclose pay information in job adverts
- Begin considering how existing pay data and job architecture would hold up if a statutory questionnaire procedure is reinstated
- Submit feedback directly, either individually or through industry and trade bodies, ahead of the 27 October 2026 deadline
The consultation represents one of the most significant potential shifts to UK equal pay law in over a decade, and its outcome will shape compliance obligations well beyond the immediate scope of the proposals themselves.
How Trusaic Can Help
At Trusaic, we provide employers in the UK and around the world with solutions to comply confidently with evolving pay equity and pay transparency requirements.
Our Pay Equity Software Suite enables compliant pay systems, ensures gender-neutral job evaluations, and automates complex reporting obligations to keep your organization one step ahead of enforcement.
- PayParity® analyzes base pay and all complementary or variable components using legally defensible, regression-based analysis, helping employers build audit-ready pay equity documentation ahead of potential mandatory review requirements.
- Remediation Optimization Spend Analysis (R.O.S.A.) works as PayParity’s remediation engine, identifying the most cost-effective way to close unexplained pay gaps.
- Salary Range Finder® helps employers build equitable, transparent salary ranges — positioning organizations ahead of a potential statutory requirement to disclose pay information in job adverts.
- Pay Decisions: Generate fair, competitive offers instantly from Workday.
- Regulatory and Pay Transparency Reporting™ captures pay equity findings and generates compliant reports across jurisdictions.
Trusaic supports organizations navigating an increasingly complex global patchwork of pay equity and pay transparency requirements, helping employers build a defensible, sustainable pay equity framework wherever they operate.
