Proposals for recruitment and equal pay enforcement
Healey said he had "heard calls" for employers to be required to disclose salary ranges when advertising jobs. The UK does not currently require salary disclosure in job ads or require employers to address gender pay gaps.
The Office for Equality and Opportunity's consultation sought views on reforming the equal pay framework for workers, businesses and the justice system. It opened at 2 p.m. on July 14, 2026, and closed at 5 p.m. on October 27, the day before the Budget, after 15 weeks.
Under the proposals, all employers would have to publish pay information in job ads. If a role were not advertised, candidates would have to receive that information in writing before an interview. Other proposals would restore a statutory questionnaire procedure specifically for pay discrimination cases and create an Equal Pay Regulatory and Enforcement Unit.
Tribunal resources under scrutiny
Tania Goodman, partner and head of employment at Collyer Bristow, told City AM the move is "a further step in its wider programme of workplace reform and may help shine a light on pay disparities that have previously gone unchallenged".
But Goodman questioned whether the Budget provided the investment needed to support those reforms. "New rights and obligations inevitably lead to greater scrutiny of workplace decisions and the potential for an increase in disputes and claims," she said. She argued that the government must ensure enforcement bodies have adequate resources.
"Without corresponding investment in the tribunal system, there is a real risk that the benefits of new legislation will be undermined by unacceptable delays in practice," Goodman said.
The government's consultation document describes an equal pay system already burdened by delays. Such cases typically exceed 10,000 a year, making equal pay one of the largest categories of Employment Tribunal complaints. The document calls the framework "excessively complex, costly, and protracted": tens of thousands of claims remain stuck in the system, and cases can take a decade or longer to resolve.
The pay gap and the watchdog's demands
Figures published by the Office for National Statistics on October 22 in "Gender pay gap in the UK: 2026" put the gap among full-time employees at 6.8% in April 2026. That was down from 7.2% in April 2025, compared with 9.4% a decade earlier and 16.4% 25 years earlier.
Median gross hourly earnings, excluding overtime, were £21.51 for men working full time and £20.05 for women. The ONS cautions that these provisional 2026 figures compare average earnings across all jobs; they do not measure whether people receive equal pay for the same job.
The Equality and Human Rights Commission welcomed the consultation but called for additional protections. It wants employers barred from asking candidates about either their salary history or their pay expectations during recruitment, as well as a right for workers to see colleagues' pay details.
EHRC chair Dr. Mary-Ann Stephenson described publishing salaries in job ads as a positive step, while saying employers should not be allowed to ask about past pay or expectations. In its response, the watchdog cited 2021 Fawcett Society research in which 58% of women and 54% of men felt that questions about previous earnings had led to a lower wage offer.
Uneven rollout of EU rules
British multinationals with employees in EU countries also face an uneven rollout of the bloc's pay transparency requirements. The directive does not apply in the UK, but it affects their operations across the continent.
The EU rules require member states to make companies disclose starting salaries and pay ranges in job listings, with gender pay gap reporting required of some businesses. Their purpose is to secure equal pay between men and women for equal work, or work of equal value, across all 27 member countries.
National governments were due to incorporate the directive into domestic law by June 7, 2026. Only a few, including Italy, Lithuania, Malta and Slovakia, met that deadline. Clifford Chance partner Amy Bird previously told City AM that the "patchwork" of implementation makes compliance difficult: some countries have introduced the rules, while many have delayed or have yet to implement them.
Article 5(2) of Directive (EU) 2023/970 prohibits employers from asking applicants about current or previous remuneration at any point in hiring. That includes base salary, bonuses and other benefits. Questions about salary expectations remain permissible, according to Personnel Today, so the EHRC's proposed UK ban on those questions would go further than the EU directive.
The directive phases in gender pay reporting by workforce size. Employers with at least 250 workers must report annually beginning June 7, 2027. Those employing 150 to 249 people must report every three years starting on the same date; for employers with 100 to 149 workers, that three-year cycle begins June 7, 2031.
A pay gap of at least 5% triggers a requirement for a joint pay assessment with employee representatives if it cannot be justified by objective, gender-neutral criteria and remains unresolved after six months.
