I have spent nearly two decades working with organisations on ethnicity pay gaps. And the single most important thing I can tell you is this: the number you will publish is not the problem. It is the symptom.

The gap in your report reflects decisions made years before you ran the analysis. Who got sponsored for the high-visibility project. Who was read as confident rather than difficult in a promotion panel. Whose potential was spotted early and invested in – and whose was quietly overlooked. You cannot close that gap by adjusting salaries. You close it by changing who reaches senior roles, and how.

This matters right now because mandatory ethnicity pay gap reporting is coming – and sooner than many organisations realise. On 25 March 2026, the government published its consultation response, confirming its commitment to introduce mandatory reporting for all UK employers with 250 or more employees through the forthcoming Equality (Race and Disability) Bill. A precise implementation date has not yet been set, but the direction of travel is unambiguous, and the draft legislation is already written. The organisations that will be best placed are those that start now – not those that wait for a deadline to force their hand.

When reporting does land, your numbers will sit alongside your competitors’, your peers’, and your public sector counterparts’, visible to employees, candidates, investors, and journalists. Board members will ask harder questions. Talented people from underrepresented backgrounds will read your data before they accept your offer. The accountability that voluntary reporting never quite delivered is arriving regardless.

It is also worth noting that the same legislation confirms mandatory disability pay gap reporting alongside ethnicity. For many organisations, that will feel like two separate workstreams. But the most forward-thinking employers will recognise something important: identity is intersectional. An employee who is Black and disabled does not experience those things separately – and a reporting framework that treats them separately will only ever tell part of the story. The organisations that approach both reports through an intersectional lens, rather than running parallel compliance exercises, will build a more accurate picture of their workforce and a more effective response to it.

The question is not whether to act. It is whether your action will be structural or cosmetic – and whether you will be ahead of the curve or scrambling to catch up.

Why most organisations get this wrong

The most common mistake is developing the individual and hoping the system follows.

Organisations invest in talent programmes for their underrepresented employees. Those employees return to unchanged line managers, unchanged promotion panels, and unchanged cultures. The ceiling holds. The gap persists. Three years later, they run the programme again.

I have seen this pattern more times than I can count. And I understand why it happens – developing individuals feels tangible, measurable, safe. But you cannot shatter a glass ceiling by only developing the people hitting it.

Genuine progress requires working at three levels simultaneously.

First, with the talented individuals themselves – building visibility, voice, leadership skills, and the confidence to advocate for their own progression.

Second, with their line managers – equipping them to sponsor rather than simply manage, to open doors and amplify voices rather than gatekeep opportunity.

Third, with senior leaders as active sponsors – people with the authority to remove systemic barriers, model accountability, and drive real change from the top.

When all three levels develop together, things shift. When only one does, they rarely do.

This is the foundation of our Tri-Level™ framework, and it is why our programmes deliver where others stall.

What the data actually shows

At Coventry City Council, when we began working together, people from Black, Asian and minority ethnic backgrounds represented just 19% of total headcount – and that percentage fell as seniority increased. That is not a pay administration problem. That is a systemic progression problem.

We designed a bespoke Brilliant Leaders programme working with 15 talented individuals alongside their line managers and senior sponsors. Thirty per cent of participants were promoted during the programme itself. Confidence in talking openly with managers about race in the workplace rose by 43%. Every single participant said they would recommend it to a colleague.

At Centrica, after an eight-month programme working across all three levels, confidence in discussing race at work rose by 79%. Senior leaders’ confidence in creating growth opportunities for their people rose by 23%. Ninety-three per cent of participants said they would recommend the programme.

At Citizens Advice, participants’ ability to communicate for career success rose by 30%. Their comfort in asking for feedback rose by 29%.

These are not one-off results. They are what happens when organisations commit to systemic change rather than surface intervention.

What it looks like to work with us

We start by listening. Before we recommend anything, we invest time understanding your culture, your challenges, and your specific gaps – because a programme designed for one organisation rarely fits another.

From there, we design a response that addresses your situation at all three levels. For organisations facing mandatory reporting, that typically means a granular analysis of where your gap actually lives – by seniority, function, and tenure – followed by a structured intervention that develops your talent pipeline and the systems around it simultaneously.

Most of our clients work with us for two to three years. We do not deliver a programme and disappear. We stay engaged, adjust as needed, and remain accountable to the outcomes we agreed together. Our Inclusive Leadership programmes – including Brilliant Leaders, #IWillAccelerate, Ascend, and Allyship – are all built on this principle.

If you are not ready to commit to a full programme, many clients begin with a 90-minute to half-day intensive session. It is a genuine starting point, not a sales exercise – and it will give you a clear picture of where your gap is and what would actually move it.

The organisations that will come out ahead

Mandatory reporting creates a public record and a basis for comparison. That is not a threat for organisations willing to do the real work. It is an opportunity to demonstrate genuine commitment, build trust with their workforce, and attract the diverse talent that everyone is competing for.

The organisations that treat this moment as a real reset will build stronger pipelines, earn the trust of their people, and create cultures where diverse talent does not just survive but thrives.

The ones that treat it as a compliance exercise will publish a number, face difficult questions from their board, their employees, and their candidates – and find themselves repeating the cycle in three years’ time.

I know which conversation I would rather be having. And I suspect you do too.

Ready to close your gap?

If mandatory reporting is on your agenda and you want to move beyond compliance into genuine, lasting progress, let’s talk.

Many organisations begin with a complimentary conversation to understand where their gap lives and what would actually move it.

Email aiko.sato@jennygarrett.global to start the conversation, or visit jennygarrett.global to learn more about our Inclusive Leadership programmes.

Frequently asked questions

What is the ethnicity pay gap and how is it different from the gender pay gap?

The ethnicity pay gap measures the difference in average pay between white employees and employees from ethnic minority backgrounds across an organisation. Like the gender pay gap, it is not primarily about people being paid differently for the same role. It is about who reaches senior and higher-paid positions – and who does not. The ethnicity pay gap is often more complex than the gender pay gap because a single headline figure can mask significant disparities between different ethnic groups within the same organisation. Disaggregated data tells a more honest story.

Is ethnicity pay gap reporting mandatory in the UK?

Not yet – but it is coming, and the government’s commitment is now firmly on the record. On 25 March 2026, the government published its response to its consultation on mandatory ethnicity and disability pay gap reporting, confirming it will legislate for all employers with 250 or more employees through the Equality (Race and Disability) Bill. The draft legislation has already been written. A specific implementation date has not been set – best current estimates put it at 2027 at the earliest – but the direction is clear and the groundwork takes time. Organisations that start preparing now will be in a significantly stronger position than those that wait for the legal obligation to force their hand.

What causes the ethnicity pay gap?

The primary driver is underrepresentation of ethnic minority employees in senior and higher-paid roles – not pay discrimination for the same work, though that exists too. The gap reflects the accumulated effect of bias in recruitment, promotion, sponsorship, and development decisions over time. Closing it requires addressing those systems, not just the payroll.

What should organisations do to close their ethnicity pay gap?

Effective action operates at three levels simultaneously. First, invest in the development of talented people from underrepresented groups – building confidence, leadership skills, and visibility. Second, equip line managers to sponsor rather than simply manage, creating real opportunities rather than goodwill. Third, engage senior leaders as active sponsors who remove systemic barriers and drive accountability. Developing only the individual without changing the system around them is the most common reason ethnicity pay gap programmes fail to deliver lasting change. Our Tri-Level™ framework addresses all three levels at once.

How long does it take to close an ethnicity pay gap?

There is no single answer, but organisations working with Jenny Garrett Global typically see measurable confidence and capability shifts within three to six months, and promotion impacts within six to twelve months. At Coventry City Council, 30% of participants in our Brilliant Leaders programme were promoted during the programme itself – an eight-month intervention. Systemic cultural shifts take longer, typically one to three years of sustained commitment. We will always give you an honest assessment of realistic timelines during our initial conversation.

How do I choose an ethnicity pay gap consultant in the UK?

Look for a consultant with a track record of measurable outcomes – not just awareness training, but evidence of progression, promotion, and cultural change. Ask whether their approach works at multiple levels of the organisation simultaneously, or only with the individuals facing barriers. Ask for case studies with specific data. At Jenny Garrett Global, we work with organisations including Centrica, Coventry City Council, and Citizens Advice, and we publish our results openly.

Can a small team engage Jenny Garrett Global, or do you only work with large organisations?

We typically work with organisations of 1,000 or more employees, including FTSE 500 companies, NHS trusts, local government, and large charities. Many clients begin with a 90-minute to half-day intensive session before committing to a full programme. If you are unsure whether we are the right fit, email aiko.sato@jennygarrett.global and we will be straightforward with you about what would work best for your context and size.

Jenny Garrett OBE is the founder and CEO of Jenny Garrett Global, a boutique leadership development consultancy in its 20th year. She is the author of Rocking Your Role and Equality vs Equity, and co-author of the forthcoming AI for Equity (Emerald Publishing, October 2026). She hosts the AI for Equity podcast.