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Direct Request (CEACR) - adopted 2025, published 114th ILC session (2026)

United Kingdom of Great Britain and Northern Ireland

Equal Remuneration Convention, 1951 (No. 100) (Ratification: 1971)
Discrimination (Employment and Occupation) Convention, 1958 (No. 111) (Ratification: 1999)

Other comments on C111

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In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on equality, the Committee considers it appropriate to examine the Conventions Nos 100 (equal remuneration) and 111 (discrimination in employment and occupation) together.

Convention No. 111 – National policy to promote equality of opportunity and treatment in respect of employment and occupation

Article 1(1). Discrimination based on sex and disability. Sexual harassment against women workers with disabilities and against lesbian, gay, bisexual and trans (LGBT). The Committee notes the Government’s reference to the Worker Protection (Amendment of Equality Act 2010) Act 2023, which introduces a duty on employers to take reasonable steps to prevent sexual harassment, supported by forthcoming guidance from the Equality and Human Rights Commission. It also takes note of the United Kingdom Supreme Court’s April 2025 ruling in For Women Scotland Ltd v Scottish Ministers, confirming that legal sex under the Equality Act is the sex recorded at birth. The Committee requests information on how the new employer duty is being implemented – particularly measures benefiting women workers with disabilities and LGBT workers and any related enforcement action – along with details of other initiatives to prevent harassment of these groups, and an assessment of how the Court’s decision affects protections against discrimination and harassment for LGBT workers.
Discrimination based on religion. The Committee notes that the Government collects data that is not disaggregated by religion and refers to the Near Neighbours programme in England, which promotes social integration in diverse communities through youth leadership initiatives and support for local projects. The Committee asks the Government to provide information on measures specifically aimed at addressing religious discrimination and promoting equal opportunity in employment, as well as their impact, particularly regarding access to work for the Muslim community.
Articles 1 to 3. Equality of opportunity and treatment irrespective of race, colour or national extraction. Ethnic minorities. The Government indicates progress in ethnic minority employment since 2010 and the introduction of a statutory right to request more predictable work patterns under the Workers (Predictable Terms and Conditions) Act 2023. The Committee observes however that evidence from the Equality and Human Rights Commission, the United Nations Human Rights Committee and the UN Committee on the Elimination of Racial Discrimination (CERD) shows that significant racial inequalities persist, including stagnating wages and lower employment rates for some groups – particularly Black people – and continuing discrimination affecting Gypsies, Roma, Travellers and people of African or Asian descent, migrants, asylum seekers and refugees. (CCPR/C/GBR/CO/8, 3 May 2024, para. 14; and CERD/C/GBR/CO/24-26, 24 September 2024, paras 17, 25, 37). In that regard, the Committee takes note of the Government’s indication that the Equality (Race and Disability) Bill would introduce a right to equal pay for ethnic minorities and disabled people, alongside mandatory ethnicity and disability pay-gap reporting for larger employers. The Committee refers the Government to its 2018 general observation on discrimination based on race, colour and national extraction which emphasized that entrenched inequalities require proactive measures, regular impact assessments, and consultation with social partners and affected groups. The Committee asks the Government: (i) to assess the effectiveness of measures promoting equality irrespective of race, colour or national extraction and to report on results, remaining gaps and planned follow-up; (ii) to provide information on how ethnic minority workers are using the new right to request predictable work patterns; and (iii) to report on the adoption of the Equality (Race and Disability) Bill.
Racial Equality Strategy 2015–25 for Northern Ireland. The Committee notes that most actions in Northern Ireland’s Racial Equality Strategy 2015–25 have been completed, with some continuing beyond 2025. Key developments include a 2020 review of the Race Relations Order (1997) and related legislation, ongoing work with the Department of Education on racist bullying, and new guidance on Ethnic Equality Monitoring in the public sector published in May 2023. Public appointments data show very low representation of ethnic minorities, with only a few appointments out of hundreds between 2019 and 2022. The Committee also notes CERD’s concern about racist violence and intimidation by paramilitary groups deterring ethnic minorities and migrants from establishing businesses (CERD/C/GBR/CO/24-26, para. 21). The Committee requests information on the Strategy’s results in employment and occupation, obstacles to equality in both public and private sectors, follow-up actions including outcomes of the legislative review, steps to increase ethnic minority access to public appointments, and measures to address racistincidents affecting labour market access.
Equality of opportunity and treatment for workers with disabilities. The Government reports that the Access to Work programme provides people with disabilities with workplace and home support, including specialist equipment, assistive software, support workers, travel costs, and physical workplace adjustments. Adjustment Passports, including for students, help streamline access to these supports and ease transitions into employment. As of early 2024: 5.5 million persons with disabilities were employed in the United Kingdom, with a 28.8 percentage point employment gap compared to persons with no disabilities, slightly improved from the previous year. Education data show disabled people are less likely to hold a degree (25.6 per cent v. 39.9 per cent) and more likely to have no qualifications (12.9 per cent v. 5.0 per cent), though degree attainment has risen steadily since 2013/14. The Equality and Human Rights Monitor notes the employment gap has decreased over time, though the reasons remain unclear. The Committee requests information on the outcomes of the Access to Work programme, Adjustment Passports, and other measures under the National Disability Strategy, along with updated statistical data on employment and opportunities for people with disabilities.
Equality of opportunity and treatment irrespective of gender identity and sexual orientation. LGBT Action Plan and Advisory Panel. The Committee notes that several commitments from the 2018 LGBT Action Plan have continued as stand-alone policies and that the Government aims to ensure LGBT+ people are safe, included, and protected from workplace discrimination. The Committee requests information on measures implemented to promote equality of opportunity and treatment for LGBT+ jobseekers and workers in both the public and private sectors.
Equality of opportunity and treatment between men and women. The Committee notes several recent United Kingdom measures to support carers, parents, and women in the workforce. The Carer’s Leave Act 2023 introduces up to seven days of unpaid leave for employees caring for a dependent with long-term needs, with future reviews considering paid leave. The Protection from Redundancy (Pregnancy and Family Leave) Act 2023 extends redundancy protection during pregnancy and family leave. Employers with over 250 staff must also implement Menopause Action Plans. Regarding Shared Parental Leave (SPL), take-up remains low overall, with only 1 per cent of eligible mothers and 5 per cent of fathers using SPL, though those who do take it generally return to their pre-birth jobs at higher rates than parents overall. Take-up is influenced by financial constraints, pay levels, workplace culture, and sector. Flexible working remains widely available, with requests granted in 83 per cent of cases, and women continue to make greater use of flexible and part-time work. Women remain under-represented in STEM (Science, Technology, Engineering, Mathematics) roles, though participation in apprenticeships is gradually rising, and the Government has launched a pilot to support parents and carers returning to STEM careers. The Committee requests continued reporting on measures addressing occupational sex segregation, promoting women’s participation across sectors, and the impacts of SPL and flexible working policies.

Convention No. 100 – Principle of equal remuneration for men and women for work of equal value

Articles 1 to 4. Gender pay gap. The Committee notes that the 2023 Annual Survey of Hours and Earnings shows the gender pay gap among full-time employees has declined to 7.7 per cent, while for part-time employees it remains at –3.3 per cent. Overall, the gap for all employees fell to 14.3 per cent in 2023, down from 17.4 per cent in 2019. The largest reductions occurred in skilled trades, sales and customer service, and administrative occupations. Regional differences persist, with higher gaps in England compared to Northern Ireland, Scotland, and Wales, partly due to the higher proportion of women in better-paid public sector roles in Northern Ireland. Men work more overtime than women, and barriers such as occupational segregation, gender stereotyping, unpaid caregiving, and limited quality part-time or flexible jobs continue to affect pay equity. The Committee recalls that the underlying causes of the gender pay gap are closely related to equality of opportunity and treatment between men and women in employment and occupation and refers, in this regard, to its comments above on Convention No. 111. The Committee requests the Government to continue to provide information on the evolution of the gender pay gap and the prevalence of overtime, disaggregated by sex and, if possible, sector of employment.
Pay inequalities. Private and public sectors. The Committee notes that the 2023 report on the post-implementation review of the Equality Act 2010 (Gender Pay Gap Information) shows the reporting regime has increased transparency and contributed to reducing the national gender pay gap, though public understanding remains limited and only half of employers are taking effective action to close their gaps. The Committee requests the Government to provide information on the measures adopted to continue raising awareness about the gender pay gap and to promote reporting on gender pay gap by employers, including in Northern Ireland.
Articles 1 to 3. Application of the principle of equal remuneration. Pay audits. Concerning the possibility for an employment tribunal to order the employer to carry out an equal pay audit under section 139A of the Equality Act 2010 and of the Equality Act 2010 (Equal Pay Audits) Regulations 2014, the Committee notes the Government’s confirmation that employment tribunals are ordering organizations found to have breached equal pay to conduct an equal pay audit.
Collective bargaining. The Committee reiterates its request for information on whether and how collective agreements consider the principle of equal remuneration for men and women for work of equal value (such as through the introduction of objective job evaluation methods in the agreements, or the inclusion of equal pay clauses).
Enforcement. The Committee notes the Government’s indication that from 2017 to 2021 there were on average 24,122 Equal Pay cases every year. Of those cases that went to hearing, 0.2 per cent were successful while 0.8 per cent were unsuccessful. The Committee requests the Government to continue to provide information on any administrative or judicial decisions on discrimination in employment and occupation, as well as information on the number and nature of discrimination claims brought before the employment tribunals and on their outcome, including cases involving the application of the principle of equal remuneration for men and women for work of equal value.
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