Comment: The ethnicity pay gap isn’t just about numbers; it’s about who is seen, heard, and represented

23 June 2026

Reading time: 6-7 minutes

Summary: In this comment piece, Kako Mavalla, Founder of the Black Excellence in Governance Awards (BEGA), explores why recent legislative changes and emerging data mark a positive step towards reducing the ethnicity pay gap, while emphasising that this is only part of the solution. He also highlights the critical role governance professionals play in driving meaningful, lasting progress.

The debate on ethnic pay gaps has been a recurring theme for some years now. The ethnicity pay gap in the UK measures the difference in average earnings between ethnic minority employees and white employees, reflecting broader inequalities in pay, seniority, and access to high-paying roles. Until recently, ‘real’ progress has often felt frustratingly slow.

This year, the UK Government committed to introducing mandatory pay gap reporting for ethnicity and disability for large employers, representing a significant development. Under the proposed changes, businesses with 250+ employees will be required to publish ethnicity and disability pay gap data, disclose workforce data, and develop action plans to address any identified gaps.

This feels significant, and yet reporting will not solve the problem. The real value lies in what organisations do next. It is time to translate insight into targeted, measurable action plans that address the structural drivers behind the data.

A visibility problem vs a pay problem

Ethnicity pay gaps are often viewed as a pay issue. More often, they are a reflection of who progresses within an organisation, it signals who is being progressed, who receives sponsorship, who is identified as future leadership talent, who gains exposure to senior decision-makers, and ultimately who occupies positions of influence and leadership.

Viewed through this lens, the pay gap is not so much just a compensation problem and more the evidence and outcomes of decisions made throughout the employee lifecycle. When certain groups are under-represented in senior management, executive leadership, and the board, disparities in pay can become a symptom rather than the root cause of the problem.

The data can show us where the gap exists but it does not show how organisations are making meaningful progress to address the underlying causes.

This is where governance comes into the equation.

Elevating the ethnicity pay gap to the boardroom

For this to become a catalyst for change, ethnicity pay gap reporting must be treated as a board-level matter, not solely an HR or compliance topic. This is where the company secretary plays a pivotal role. Governance professionals are uniquely positioned to ensure that pay gap insights are not siloed, but become integrated into core board discussions.

In practical terms, this means:

Ensuring ethnicity pay gap reporting is formally considered by the board and its committees, particularly the nomination and remuneration committees.
Connecting pay gap data with succession planning, leadership development, and risk discussions.
Framing disparities as indicators of potential governance, culture, and oversight issues.
Facilitating cross-functional alignment between HR, legal, DEI, and executive leadership so that the board receives a coherent and holistic view.

This allows boards to assess whether their organisation is building a sustainable, diverse leadership pipeline.

Looking past the data

Governance professionals offer an unique experience, the ability to see beyond outcomes and recognise the systems that produce them. Boards do not just look into a breach when it is a regulatory failure, they actively interrogate the control, oversight and decision-making processes allowed it to occur. Ethnicity pay gap data needs to be looked at in the same way. With that in mind, the most valuable question is not “What is our pay gap?”

It is:

"What does our Pay Gap tell us?
"Is there a mix of talent coming into the organisation and not advancing?"
"Do succession plans rely on the same talent pools over and over again?"
"Is there a subset of employees who are able to use informal networks, whereas another subset is not?"
"Who are the people getting top-notch assignments and executive exposure development?"
"Which employees are they looking at as potential leaders?"

As more details become available about the incoming mandatory ethnicity pay gap reporting, governance professionals will have the opportunity to explore the technicalities further. While it is natural to look to the experience of gender pay gap reporting for insights into what works, and opinions are, in fact divided on its effectiveness. On thing is clear that the ethnicity pay gap reporting will raise its own unique issues that deserve careful consideration.

How can governance professionals support boards to conduct deeper discussions about representation throughout the leadership pipeline? By using the data as a starting point.

This includes examining:

Executive and board succession planning;
Leadership development programmes;
Promotion and progression trends;
Network opportunities for support and mentorship;
Representation in the decision-making process.

Trust, transparency and credibility

To create meaningful ethnicity, and disability, reporting, organisations must create an environment where employees are comfortable to provide this information. Without trust, disclosure rates may be low, data quality may suffer, and we may be left making decisions based on incomplete data. To an extent, some employees may question the credibility in the methodology itself, in particular, where broad ethnicity categories may not fully represent the diversity of employee experiences.

Employees are entitled to ask:

"Why is this information being collected?"
"How will it be used?"
"Who will have access to it?"
"What changes will result from the findings?"
"Does any of this categories truly represent me?"

Boards should recognise that transparency and trust go hand in hand. Workforce data can be published however without accountability, scepticism persists. When there are credible actions published with data, there is confidence. If people can see that information is being used to inform changes, not just for regulation's sake then their trust in the organisation's leadership is enhanced.

The real test for boards

The element of visibility of diversity is one of the most understated elements of diversity, yet it is pivotal to shaping ambition and opportunity. Representation matters because it influences outcomes. In this context, it broadens perceptions of who belongs in leadership and who is capable of leading.

Employers in the UK now have an important opportunity to accelerate that change with the introduction of mandatory reporting on their pay gaps for ethnicity and disability. Amidst all of this, compliance will be the simplest part of the process. Data gathering, figure calculations and reports can all be done via standard processes and controls. The hard part is surfacing what solutions we can nurture beyond the data.

Data can be brought to the boardroom table by the reporting requirements; however, data is not the agent of change - governance, accountability, and sustained action are. The organisations that will benefit most will not be those that simply comply, but those that elevate the conversation: interrogating what sits behind the data and acting on it with intent and discipline.

How can organisations ensure real lasting change? Not by what they report, but by what they are willing to confront - and change - once those insights are visible.