FTSE 100 disability reporting is still at its 2021 level of 12 companies

Twelve FTSE 100 companies published a disability representation figure in 2021, and twelve publish one now, by ActionAble's count ^[1][3]. Only four companies are on both lists ^[4]. Eight of the 2021 reporters have dropped out of the count, and eight of today's twelve are new since then ^[14][15]. The Personnel Today account of the report does not say how many of the eight left the index and how many stayed in and stopped publishing ^[14]. So the number that quietly abandoned the work is unknown.

For a board, the retention figure says more than the total. A flat twelve looks like inertia. Underneath it, some companies started and others fell away, and one in three of the 2021 reporters still publishes ^[16].

The coming rule asks for more than a headcount share. A disability pay gap compares the pay of staff who have declared a disability with the pay of those who have not. A company needs declarations matched to payroll before it can report one. Eighty-eight companies publish no baseline for the share of their workforce that is disabled or has a long-term health condition ^[2]. The finding is about publication: a company can hold the figure internally without releasing it. ActionAble said the gap leaves companies unprepared for mandatory reporting and "potentially" unsighted on parts of workforce inclusion ^[6]. "Boards cannot manage what they cannot see," Sara Weller, the group's co-founder, said ^[8].

The case for waiting is real, and ActionAble is arguing against it. The government has committed to mandatory disability and ethnicity pay gap reporting for large employers but has set no official timeline ^[5]. A board that publishes now releases a number built on whatever declaration rate it has, before the regulation that sets the method has been announced ^[13]. ActionAble wants companies to begin anyway, under a principle it calls "progress not perfection": measure, publish, learn and improve over time ^[11]. "You do not need perfect data to make a start. You need leadership, transparency and a willingness to learn," Weller said ^[9].

Both paths cost something. Publishing early puts an imperfect figure in public and commits the company to repeating it, and only four of the 2021 cohort are on record as still doing so ^[4]. Waiting keeps the imperfect figure private. It also means the first number the company releases is the one the rule requires, with no earlier year beside it.

Nothing forces a decision this quarter ^[5]. In my view, the choice made this year sets what a company can show when the rule lands. It will have either a 2021 figure and a current one, as the four persistent reporters do, or a single first-year number ^[4]. Weller, whose organisation compiled the Index, addressed both government and boards ^[7]. "But the overall picture has barely moved in five years. The government now needs to provide clarity around mandatory reporting, and Boards need to start preparing," she said ^[10].