Ethnicity Pay Gap Reporting: What the NHS Review Means

In August 2025, the NHS Race and Health Observatory announced it had commissioned the University of Surrey to lead a review into ethnicity pay gap reporting across the NHS in England. This landmark investigation, which represents the first of its kind in the service, comes following worrying trends regarding the imbalance between overall workforce diversity and representation at senior levels.

Below, we examine the review in more detail and discuss what it hopes to achieve. We then explore the perspectives of leaders across health and employment, and how better reporting could benefit employees.

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The Aims of the NHS Ethnicity Pay Gap Reporting Review

Running for 18 months until December 2026, the ethnicity pay gap reporting review of NHS England will examine whether unwarranted inequalities in pay, progression or pensions exist between staff of different ethnicities. Where such disparities are identified, the review will also seek to determine their causes and provide recommendations to address them.

This initiative comes against a backdrop of persistent underrepresentation of Black, Asian and minority ethnic (BAME) staff in senior roles. The NHS is one of the most ethnically diverse employers in Europe. Despite this, only 7.9% of its very senior management positions were held by BAME staff as of September 2024. Consequently, while diversity is evident across the wider workforce, it’s far less visible at the top, creating a wage difference that continues to disadvantage BAME staff.

To help overcome this NHS pay gap, the University of Surrey-led review will combine quantitative data, mirroring aspects of gender pay gap reporting, with qualitative research into the lived experiences of workers. This approach aims to provide a comprehensive understanding of the inequality issues, with a final report due in December 2026.

What Leaders are Saying About the Review

Following the announcement of the NHS ethnicity pay gap reporting review, voices from within and outside the service have provided their take. Many have emphasised its urgency and explained why it’s important.

For example, Mr Owen Chinembiri, Assistant Director of Workforce at the NHS Race and Health Observatory, outlined the ineffectiveness of past initiatives. He stated that previous improvements were “slow, patchy and frustrating,” leaving many BAME employees with continued hurdles to career progression. He added, “Tackling these inequalities is now an urgent matter that requires our collective understanding and action.”

Elsewhere, Mr Danny Mortimer, Chief Executive of NHS Employers, welcomed the review. He said, “The delivery of a better NHS and a healthier nation requires the best use of all the talents in our workforce.” He stressed that “inequalities and racism” mustn’t jeopardise this and said the report will help address equal pay for minorities.

From the academic side, Professor Carol Woodhams, Professor of Human Resource Management at the University of Surrey and co-lead of the review, framed the research as an opportunity for transformative change. She discussed her previous experience in this area and stated this “vital review” provided the opportunity to “uncover the root causes of ethnic disparities in NHS pay and progression.”

Finally, taking a perspective from outside the NHS, Ms Helga Pile, Acting Head of Health at UNISON, highlighted the barriers faced by BAME employees. She noted that nearly a third of NHS England staff come from BAME backgrounds. Yet, many struggle to secure senior positions compared with their white colleagues. As a result, she stated, “Understanding all the root causes is essential to wiping out disadvantage.”

Together, these insights underline the importance of the review in identifying systemic barriers and guiding evidence-based action. This will not only help to ensure fair pay but also boost career progression opportunities for all NHS staff.

How Better Pay Gap Reporting Can Benefit Employees

Gender pay gap reporting has been mandatory for UK employers with 250 or more staff since 2017. The same cannot be said for disability and ethnicity pay gap reporting. The government has previously discussed introducing such measures. However, none are currently in place, and only a handful of NHS trusts voluntarily publish their ethnicity pay data.

While this is a step in the right direction, without consistent, mandatory reporting, it remains extremely difficult to track the NHS pay gap, implement meaningful changes, and ensure accountability regarding wage differences. With mandatory reporting, there could be:

• Improved Visibility of Inequalities: Regular publication of pay data broken down by ethnicity would make it harder to ignore wage differences between white and BAME staff. This increased transparency could prompt greater accountability and drive real change.
• New Policy Developments: With a clearer picture of the factors preventing equal pay, NHS organisations would be better placed to design and implement proactive measures to promote equality.
• More Informed Career Choices: Staff would be able to consult a trust’s ethnicity pay gap records when making career decisions. This transparency would empower employees and incentivise trusts to make meaningful improvements to attract and retain top talent.

From a legal perspective, ethnicity pay gap reporting would also complement the Equality Act 2010. This legislation prohibits discrimination based on protected characteristics, including race. Public reporting could therefore encourage organisations to address disparities proactively, reducing the risk of legal enforcement and supporting compliance with equality legislation.

Ultimately, consistent and transparent ethnicity pay gap reporting would not only highlight where inequalities exist but also provide the foundation for targeted action, helping to create a fairer, more inclusive NHS workforce.

Get Help with Redmans

If you’ve any questions about equal pay for minorities or believe your rights have been breached, contact Redmans Solicitors today. Our team of specialists is here to help, and following a brief consultation, we can discuss how you can proceed.

To begin your journey with us now, simply:

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