Views • 5 November 2026
Building a strategic framework for DEI’s New Era
Boardrooms have no shortage of business-critical issues competing for attention at the moment. One that risks becoming overshadowed is the changing Diversity, Equity and Inclusion (DEI) landscape and the growing expectation on employers to understand, explain and address workforce inequalities.
In March 2026, the Government published its response to the consultation on mandatory ethnicity and disability pay gap reporting, including indicative draft clauses in Annex A. The proposed framework would apply to employers with 250 or more employees and would broadly align with existing gender pay gap reporting. It would also introduce workforce-composition reporting and employee declaration rates. The detail is still developing, with primary legislation and supporting regulations still required, so employers should prepare without treating every element as settled law.
Alongside this, the Employment Rights Act 2025 creates the enabling power for Equality Action Plans. Employers with 250 or more employees can publish a voluntary plan during the 2026–27 reporting year and, subject to further legislation, these are expected to become mandatory from spring 2027. Plans currently focus on addressing the gender pay gap and supporting employees experiencing menopause. The Government also intends, when the ethnicity and disability reporting regime is introduced, to align the requirements so that a single Equality Action Plan can cover sex, race/ethnicity and disability.
Taken together, these developments point towards greater transparency and accountability. Organisations will increasingly be expected not only to publish data, but to understand what sits behind it and show what they are doing in response.
Act, then test
At MAPP, we see an opportunity in that shift. Data can tell an organisation where to look, but rarely what to do. Meaningful progress comes from combining robust measurement with an understanding of lived experience: how people are recruited, managed, given opportunities, recognised, supported and enabled to progress.
Transparency of course is not transformation. An aggregate pay gap can reveal an important pattern, but it does not explain the mechanism producing it. The answer is not to jump from a headline number to a fashionable intervention but rather to diagnose. Recruitment, role segmentation, access to stretch opportunities, progression, retention, working patterns, pay structures and leadership decisions can all shape outcomes. A useful discipline is simple: measure, diagnose, act, then test whether the action worked.
For real estate, this matters particularly. Diversity challenges remain evident at senior levels, while wider sector research has highlighted socioeconomic under-representation. Preparing for greater reporting will require sound HR systems, governance and data capability, alongside expertise to collect and interpret detailed workforce information. Employers must also consider how policies, management capability and workplace practices support employees experiencing menopause.
Collecting good-quality data, however, is far from straightforward. In fact, data quality is partly a cultural issue.
Standardised categories are necessary for meaningful comparison, but they compress complexity. The Government’s proposed ethnicity framework uses harmonised classifications and requires at least a binary comparison for published reporting. That has value, but aggregated figures may obscure different experiences within broad groups. The principle should be: standardised reporting for comparability, with more granular analysis where lawful, statistically meaningful and useful.
Disability reporting makes the link between culture and data even clearer. The proposed framework includes employee self-declaration rates as well as headline pay-gap measures. If employees do not feel confident disclosing a disability, the data may understate the workforce reality. Trust therefore becomes part of the data infrastructure. A declaration rate is not just an administrative metric; interpreted carefully, it can prompt questions about whether employees understand why information is collected and feel confident about how it will be used.
Spot the patterns
Trust cannot rest on reassurance alone though. Organisations need clear data governance: why information is requested, how it will be protected and aggregated, who genuinely needs access and how insight will influence decisions. Ethnicity and health information can involve special-category personal data, so disclosure should be designed with appropriate legal and data-protection expertise.
Well-crafted Equality Action Plans can turn insight into disciplined action. Short-term priorities might include improving data quality, governance and employee communication. Medium-term work should examine systems affecting opportunity: recruitment, promotion, access to high-value assignments, sponsorship, flexible working, pay and retention. Longer-term strategies can address the pipeline through entry routes, career architecture and sustained outreach.
Management capability is an important lever, but not a universal cure. Demographics do not automatically improve because an organisation has a strong leadership programme. Managers influence inclusion through the everyday allocation of opportunity, feedback and support, but their behaviour sits within wider systems. Strong organisations therefore develop inclusive managers while examining whether processes and incentives support fair outcomes.
Transparency is not transformation. Meaningful progress comes from combining robust measurement with an understanding of lived experience.
A further challenge is ensuring ethnicity, disability and gender reporting are not treated as separate compliance silos. People’s experiences can be shaped by more than one characteristic, while small cohorts create analytical and privacy limitations. Where internal teams lack specialist capability, or independent scrutiny would help test assumptions and reduce confirmation bias, external experts can add value by challenging analysis and helping organisations examine the evidence holistically.
Ultimately, regulation and individual corporate action can only achieve so much. Real estate also needs collective action. The task is not to move away from valuable initiatives such as Real Estate Balance and Pathways to Property, but to build on them and increase their reach. No single programme can change the sector’s talent market or reputation alone.
That means coordinated efforts to engage schools, youth employment not-for-profits, universities and communities historically outside the industry’s recruitment footprint, while making the breadth of real estate careers more visible and accessible. It also means ensuring the experience people encounter once they enter the sector matches the promise made during recruitment. Employer brand is built through evidence and experience, not slogans.
The emerging legislation creates a stronger framework for transparency; it is not the solution in itself. Data will reveal patterns. Good organisations will investigate what is driving them, act with discipline and measure whether actions make a difference. The employers that lead in this next era of DEI will combine evidence, trust, fair systems and accountable leadership to make inclusion part of how work is actually done.