Just 12 FTSE 100 companies publish disability data, as pressure grows on employers to prepare for mandatory pay-gap reporting, according to new research.
Most of Britain’s biggest companies still do not publicly disclose how many disabled people they employ, despite growing pressure on employers to prepare for mandatory disability pay-gap reporting. The Disability Index FTSE 100 2026, developed by ActionAble in partnership with the DFN Charitable Foundation, The Valuable 500 and ImpactMatch, found that just 12 FTSE 100 companies publish quantitative data on disability representation. That means 88 of Britain’s largest listed companies have no publicly available numerical baseline showing disability representation within their workforce.
More importantly, the overall number has barely changed in five years. Twelve FTSE 100 companies were also publishing disability representation data in 2021, and only four of those original companies are still doing so today. The findings suggest that better disability data is becoming both a business and governance issue as employers rethink talent strategies and prepare for proposed mandatory disability pay-gap reporting.
The Disability Index examines publicly available disability reporting across the UK’s 100 largest listed companies. It looks at measures including disability representation, declaration and response rates, disability pay-gap reporting, numerical targets and the visibility of disability data within corporate reporting.
DISABILITY INCLUSION MATTERS
For Sara Weller CBE, Co-Founder of ActionAble, the lack of progress represents a significant missed business opportunity: “Disability inclusion is the business equivalent of an open goal. Businesses are rethinking their talent strategies in a post-AI world. Growth is the missing link in many business plans. Greater inclusion of people with disabilities helps attract and retain new talent with new ways of thinking. And businesses who better understand the diverse needs of around 1 in 4 customers who are disabled will build loyalty amongst a consistently underserved customer group.”
ActionAble describes this potential commercial upside as the “Disability Dividend” – the value businesses can unlock through better inclusion of disabled employees and customers. Around one in four people in Britain reports a disability, making disability inclusion relevant not only to workforce strategy but also to customer experience, product design and commercial growth. That shift was also reflected in The Valuable 500 and BBC StoryWorks’ All In series, which highlighted the importance of lived experience in shaping more inclusive organisations.
FEW COMPANIES DISCLOSE DISABILITY DATA
Even among the 12 companies publishing quantitative disability information, disclosure remains inconsistent. Only:
- Five include disability metrics in their annual report and accounts
- Three publish a disability pay gap
- Three have an explicit numerical disability target
- One reports against all 10 measures assessed by the Index
That raises a wider question about whether boards currently have enough information to understand disability representation and identify gaps in recruitment, progression, retention or pay. “Boards cannot manage what they cannot see. Building an understanding of how disability is represented inside the business, helps fuel progress,” said Weller. “Our case studies show how positive improvements can be made wherever the business starts from. It is progress not perfection that counts.”
LACK OF DISCLOSURE AND DISABILITY REPORTING
The lack of movement is particularly notable because awareness of both disability and neurodiversity has increased considerably. Back in 2023, Fair Play Talks reported that around half of UK employers did not disclose the number of disabled people in their workforce. But greater awareness has not yet translated into consistent reporting.
Asked why, Weller told Fair Play Talks: “Just twelve FTSE 100 companies report disability representation data, a figure that hasn’t changed in five years. Though awareness of disability has improved in this time, this has yet to translate into action. The reasons for this are twofold. First, too many boards still see disability as a compliance issue, not a business opportunity as our Disability Dividend report shows. When disability inclusion is not taken as a priority, attempts to introduce disability reporting will be of limited success. In fact, reporting momentum has regressed in several cases: just four of the companies who reported in 2021 also did so in 2026.
“The second reason depends on workplace culture,” explained Weller. “The decision to declare a disability is deeply personal and depends on an individual’s trust in the organisation. To unlock accurate disability representation data, businesses must ensure their employees feel empowered to bring their full selves to work. In practice, this means implementing better inclusion initiatives, supporting staff networks and listening to lived experience across the organisation – we talk about feeling ‘safe to share’.”
BETTER DATA DEPENDS ON TRUST
That idea of being “safe to share” is central to the reporting challenge. Employers cannot simply ask employees to disclose disability and assume the resulting figure represents the true composition of the workforce. Previous global research found that trust is fundamental to understanding the needs of disabled employees. And separate research has shown that many employees still fear disclosing invisible disabilities at work.
The Index therefore raises an important distinction between representation, declaration and response rates. An organisation may employ significant numbers of disabled or neurodivergent people but still record low disclosure if employees do not feel confident about what will happen after they share that information. That is particularly relevant for non-visible disabilities and neurodivergence.
Recent research found that neurodivergent employees continue to report poorer workplace experiences despite greater organisational focus on inclusion. Building better data therefore means explaining:
- why disability information is being collected;
- how it will be used;
- who will have access to it;
- how confidentiality will be protected;
- what support is available; and
- what action will follow from the findings.
WHY EMPLOYERS SHOULD NOT WAIT FOR MANDATORY REPORTING
The findings come as the UK moves towards mandatory disability and ethnicity pay-gap reporting for large employers. Weller warns companies against waiting until legislation forces them to act. Asked about the biggest risk, she said: “Companies who wait for mandatory disability pay-gap reporting will be starting from nothing at the moment they need to have answers. Without having done the work to build trust, outcomes will be hindered by low declaration rates and unreliable figures. The result is data that is difficult to interpret and hard to defend.
Still, the biggest opportunity “is commercial”, she noted. “Around one in four people in Britain report a disability. That’s a huge share of your customers, your existing workforce and your potential talent pool. When businesses wait, they continue to misunderstand that market and lose out on talented people. Boards cannot manage what they cannot see. The companies that start now will have adjusted, learned and improved by the time regulation arrives. If companies wait, they will be unprepared.”
The warning shifts the issue away from compliance alone. Companies that wait may eventually be able to produce a number, but without having built trust and increased declaration rates beforehand, that figure may provide limited meaningful insight.
BDF URGES EMPLOYERS TO START PREPARING NOW
Business Disability Forum (BDF) is also urging employers to use the period before legislation is finalised to review how they collect, analyse and act on disability data. “The drafting of the Equality (Race and Disability) Bill may require employers with 250 or more employees to report the percentage of their workforce who have a disability and the percentage pay gap between disabled and non-disabled employees. Many employers already collect data to some extent, but we don’t yet know details of how employers will need to do this moving forward,” said Angela Matthews, Director of Public Policy and Research at Business Disability Forum.
“While we are waiting on the detail, employers can start thinking about their data collection, analysis and reporting cycles, based on the Government’s proposals that employers will be reporting their data in April each year. Employers should also continue to support and build good relationships with disabled employee networks who can be a huge support to employers needing to fulfil these requirements,” advised Matthews.
For those who already know and report their disability pay gap, “they can already be thinking about why those gaps exist and what they are going to do as a result”, added Matthews. “This will help them prepare for the element of the Bill that proposes employers report that an equality action plan. Any legal requirement aside, how included and supported disabled employees feel at work every day remains more important than the numbers themselves, which only ever provide a snapshot of what is happening within an organisation.”
That final point is significant. Better reporting may reveal inequalities, but the data alone cannot show whether disabled employees feel able to request adjustments, whether managers respond effectively, whether career progression is equitable or whether employees feel safe to share disability information in the first place.
DATA SHOULD LEAD TO ACTION
For employers that already collect disability information, the next question should not simply be “what is our gap?” It should be “why does the gap exist, and what are we going to do about it?” That could mean examining differences in:
- recruitment and hiring;
- pay and reward;
- promotion and progression;
- retention;
- access to workplace adjustments;
- employee experience; and
- representation at senior levels.
It also reinforces the importance of disabled employee networks and lived experience. Rather than treating workforce data as an isolated compliance exercise, employers can use employee networks to understand what sits behind the numbers and where practical barriers remain.
INCOMPLETE DATA CHALLENGES
One reason companies may hesitate to publish disability data is the belief that incomplete disclosure produces an unreliable picture. But Weller argues that should not prevent organisations from starting.
Asked what she would say to boards worried their data was too incomplete to publish, Weller said: “This is not about naming and shaming. With the Disability Index, we want to recognise the organisations with the courage to be transparent and take the first steps towards better inclusion. At ActionAble, we encourage the principle of progress, not perfection. Businesses should take incomplete data as a learning curve, and outline a clear strategy on how to improve it by creating a culture that is safe to share.”
As we await the arrival of mandatory pay-gap reporting, “there is an opportunity for FTSE 100 companies to set an example”, noted Weller. “Unlocking this opportunity will help them recruit, retain, and progress talent, solve complex challenges, and deepen loyalty across all stakeholders.”
That approach puts the emphasis on transparency and improvement, rather than waiting until every data gap has been solved. Companies could, for example, publish both their disability representation figure and their response or declaration rate, explain the limitations of the data and set out what they are doing to improve it.
CENTRICA TARGETS 20% DISABILITY REPRESENTATION
The report also highlights companies attempting to move from measurement to action. Centrica, for example, has set a goal of reaching 20% disability representation by 2030.
“If we don’t attract people of all genders, ethnicities, abilities and sexual orientation, how can we expect to have the best team that reflects the communities we serve and helps us deliver better outcomes for our customers,” shared Chris O’Shea, Group Chief Executive at Centrica. “To reach our goal of 20% disability representation by 2030, we must listen, build trust and be transparent about the progress we’re making. Whilst our data isn’t perfect, sharing it openly keeps us accountable and helps drives the meaningful change we want to see.”
That approach reflects the broader argument behind the Index. Numerical targets can provide direction, but they depend on employees feeling sufficiently safe to share information in the first place.
DISABILITY INCLUSION IS A TALENT ISSUE
With employers reassessing workforce needs in response to AI, skills shortages and demographic change, excluding disabled talent makes increasingly little commercial sense. Barriers often arise not from an individual’s disability but from how recruitment, jobs and workplaces are designed.
Fair Play Talks has repeatedly highlighted the role workplace culture plays in determining whether disabled and neurodivergent employees can thrive. Recent research found that seven in 10 UK employers lacked disability or neurodiversity training despite growing tribunal risks. Greater representation therefore needs to be accompanied by accessible recruitment, effective workplace adjustments, informed managers and psychologically safe cultures.
The DFN Charitable Foundation, which partnered on the Index, also highlights the talent opportunity. “In our experience, when disabled people are given the right support to succeed, they become some of the most loyal and committed members of the workforce,” noted David Forbes-Nixon OBE, Founder and Chairman of the DFN Charitable Foundation. “Currently, this vast pool of capable, motivated people is being overlooked by the FTSE 100. Employers who act now will gain an advantage over those who wait.”
The wider business case extends beyond recruitment. More inclusive organisations can potentially strengthen:
- employee retention;
- productivity;
- innovation;
- customer understanding;
- accessibility;
- organisational reputation; and
- access to a substantial underserved market.
ONE IN FOUR CUSTOMERS MAY ALSO BE DISABLED
The customer dimension is significant too. If around one in four people in Britain reports a disability, companies that fail to consider accessibility risk excluding a substantial proportion of potential customers as well as employees.
That is why disability inclusion is increasingly being positioned as a business strategy rather than solely an HR or DEI programme. Organisations that better understand disabled employees may also be better equipped to identify barriers affecting customers.
WHY BOARDS NEED TO ASK BETTER QUESTIONS
The Index suggests disability data should increasingly be visible at board level. Boards should understand:
- What proportion of employees identifies as disabled?
- What proportion responds to disability-related workforce questions?
- Are there differences in recruitment, pay, progression or retention?
- Do employees feel safe to share disability information?
- What adjustments are employees requesting — and are they being delivered?
- Are managers equipped to support disabled and neurodivergent colleagues?
- Is disability represented in senior leadership and decision-making?
- How accessible are products and services for disabled customers?
Without that information, disability can remain largely invisible in business decision-making.
FROM DATA TO ACTION
The Disability Index is not simply making a case for another corporate reporting metric. Its bigger argument is that data can help organisations understand whether disabled people are entering, staying and progressing within their businesses, and whether workplace culture allows employees to identify openly without fearing negative consequences.
That distinction matters. A low disability figure may indicate low representation. But it could equally indicate low trust. The organisations best prepared for mandatory reporting will therefore be those that start addressing both issues now.
Fair Play Talks has seen that shift reflected in organisations recognised through the Disability Smart Impact Awards, where practical changes to workplace design, technology, recruitment and leadership have demonstrated how disability inclusion can move from policy into practice.
With 88 FTSE 100 companies still without a public disability representation baseline, the message from the Index is increasingly clear: Businesses do not need perfect data before they start. They need leadership, trust, transparency and a willingness to improve. And those that act early may be better placed not only for future regulation, but also to attract talent, retain employees, understand customers and unlock a significant commercial opportunity.
Click here to download the Disability Dividend report.
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